CY-07-031, Update of License Termination Plan
| ML070650478 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 02/22/2007 |
| From: | Gerard van Noordennen Connecticut Yankee Atomic Power Co |
| To: | Document Control Desk, NRC/FSME |
| References | |
| CY-07-031 | |
| Download: ML070650478 (106) | |
Text
CONNECTICT Y;',,IKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD
- EAST HAMPTON, CT 06424-3099 FEB 2 2 2007 Docket No. 50-213 CY-07-031 Re: 10CFR50.71(e)
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant Update of License Termination Plan In a letter dated July 7, 2000, as revised in August 2002 (Revision 1) and in October 2002 (Revision 1A), Connecticut Yankee Atomic Power Company (CYAPCO) submitted the Haddam Neck Plant (HNP) License Termination Plan (LTP) to the NRC as a supplement to the HNP Updated Safety Analysis Report (USFSAR). The HNP LTP was approved by the NRC on November 25, 2002, via License Amendment No. 197. In a letter dated August 19, 2005, the NRC approved Revision 3 of the HNP LTP as part of License Amendment No 202.
This revision added the Basement Fill Model. Revision 4 to the LTP, which contained updates due to decommissioning progress and other administrative changes, was submitted to the NRC in a letter dated November 16, 2006 The purpose of this letter is to submit Revision 5 to the HNP LTP as required by 10 CFR 50.71(e). The detailed description and reasons for each change is provided in Attachment 1. Revision 5 of the LTP reflects changes to survey units, current decommissioning status, and other administrative changes. This revision replaces only the effective pages for Revision 5 which are provided in Attachment
- 2. A markup of the effected pages from Revision 4 is provided in Attachment 3.
Pursuant to 10 CFR 50.71 (e)(2)(i), I certify that this revision accurately presents changes completed since our previous submittal that are necessary to reflect information and analyses associated with the changes discussed above.
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Document Control Desk CY-07-031 /Page 2 As stipulated in 10 CFR 50.71(e)(2)(ii): "This submittal shall include an identification of changes made under the provisions of Section 50.59, but not previously submitted to the Commission". The changes to the HNP LTP included in this submittal were made using the provisions of 10 CFR 50.59. Specifically, the changes were screened to determine whether the changes require a 10 CFR 50.59 evaluation. There were no 50.59 evaluations required for the changes in this submittal.
If the NRC should have any questions, please contact me at (860) 267-3938.
Sincerely, Gerard van Noordennen Date Director, Regulatory Affairs and Quality Assurance Subscribed and sworn before me This 9 day of Eebrur4 2007 Notary Public My Commission Expires: " ooq9.31.
Attachments as noted cc: S. J. Collins, NRC Region I Administrator T. B. Smith, NRC Project Manager, Haddam Neck Plant Dr. E. L. Wilds, Jr., Director, CT DEP Monitoring and Radiation Division
CY-07-031 Attachment 1 Haddam Neck Plant Update of License Termination Plan Revision 5 Detailed Description and Reasons for Each Change February 2007
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 1 Table of Various changes to mirror changes made within the Necessary to reflect changes in pagination, typos and No Contents, LTP figure designations Pages i through x 2 LEP-1, & Changed List of Effective Pages to reflect changes Self-explanatory No LEP-2 made in Revision 5 3 2-11, Changed "Sampling of the..." to "Sampling the..." Correct grammar No Paragraph 2, last sentence 4 2-12, Table Changed "(Figs 2-1 through 2-6)" to "(Figs 2-1 Reflect correct number of revised figures No 2-3, Column through 2-7)"
4 heading 5 2-16, Changed paragraph numbering from "2.1.1" to "2.3.2" Correct typo No Paragraph 2.1.1 6 2-17, Changed paragraph numbering from "2.3.2" to "2.3.3" Correct typo No Paragraph 2.3.2 Page 1 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 7 2-53, Table Changed the Figure No. for Survey Unit 9106-0001 Reflect the correct revised figure. No 2-10 from 2-4 to 2-2.
Changed the Figure No. for Survey Unit 9106-0002 Reflect the correct revised figure. No from 2-4 to 2-2; 2-3.
Changed the Figure No. for Survey Unit 9106-0003 Reflect the correct revised figure. No from 2-4 to 2-3.
Changed the Figure No. for Survey Unit 9106-0004 Reflect the correct revised figure. No from 2-4 to 2-3.
Changed the Figure No. for Survey Unit 9106-0006 Reflect the correct revised figure. No from 2-4 to 2-4; 2-5.
Changed the Figure No. for Survey Unit 9106-0007 Reflect the correct revised figure. No from 2-4 to 2-5.
Page 2 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 8 2-54, Table Changed the Figure No. for Survey Unit 9106-0008 Reflect the correct revised figure. No 2-10 from 2-4 to 2-5.
Changed the Figure No. for Survey Unit 9106-0009 Reflect the correct revised figure. No from 2-4 to 2-5.
Changed the Figure No. for Survey Unit 9106-0010 Reflect the correct revised figure. No from 2-4 to 2-5.
Changed the Figure No. for Survey Unit 9106-0011 Reflect the correct revised figure. No from 2-4 to 2-5.
Changed the Figure No. for Survey Unit 9106-0013 Reflect the correct revised figure. No from 2-4 to 2-5.
Changed the Figure No. for Survey Unit 9106-0014 Reflect the correct revised figure. No from 2-4 to 2-2.
Changed the Figure No. for Survey Unit 9106-0015 Reflect the correct revised figure. No from 2-4 to 2-5.
Page 3 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 9 2-55, Table Changed the Figure No. for Survey Unit 9302-0000 Reflect the correct revised figure. No 2-10 from 2-1 to 2-2.
Changed the Total Area for Survey Unit 9304-0001 Provide consistency between the LTP and the No from 4794 to 4800 and the Figure No. from 2-1 to 2-2. associated Final Status Survey Plan and reflect the correct revised figure.
Changed the Total Area for Survey Unit 9304-0002 Provide consistency between the LTP and the No from 1298 to 1268 and the Figure No. from 2-1 to 2-2. associated Final Status Survey Plan and reflect the correct revised figure.
Changed the Figure No. for Survey Unit 9306-0000 Reflect the correct revised figure. No from 2-1 to 2-2.
Changed the Figure No. for Survey Unit 9312-0001 Reflect the correct revised figure. No from 2-1 to 2-2.
Changed the Figure No. for Survey Unit 9312-0002 Reflect the correct revised figure. No from 2-1 to 2-2.
Changed the Figure No. for Survey Unit 9312-0003 Reflect the correct revised figure. No from 2-1 to 2-2.
Page 4 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 10 2-56, Table Changed the Total Area for Survey Unit 9312-0004 Provide consistency between the LTP and the No 2-10 from 1584 to 1586 and the Figure No. from 2-1 to 2-2. associated Final Status Survey Plan and reflect the correct revised figure.
Changed the Figure No. for Survey Unit 9312-0005 Reflect the correct revised figure. No from 2-1 to 2-2.
Changed the Figure No. for Survey Unit 9312-0006 Reflect the correct revised figure. No from 2-1 to 2-2.
Changed the Total Area for Survey Unit 9312-0007 Provide consistency between the LTP and the No from 1563 to 1566 and the Figure No. from 2-1 to 2-2. associated Final Status Survey Plan and reflect the correct revised figure.
Changed the Figure No. for Survey Unit 9312-0008 Reflect the correct revised figure. No from 2-1 to 2-2.
Changed the Total Area for Survey Unit 9312-0009 Provide consistency between the LTP and the No from 828 to 1511 and the Figure No. from 2-1 to 2-2. associated Final Status Survey Plan and reflect the correct revised figure.
Changed the Total Area for Survey Unit 9312-0010 Provide consistency between the LTP and the No from 1874 to 1365 and the Figure No. from 2-1 to 2-2. associated Final Status Survey Plan and reflect the correct revised figure.
Page 5 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 11 2-57, Table Changed the Figure No. for Survey Unit 9313-0000 Reflect the correct revised figure. No 2-10 from 2-1 to 2-2.
Changed the Survey Area Code Description for Survey Provide consistency between the LTP and the No Area 9504 from "Bypass Road/secondary Parking lot" associated Release Record.
to "Bypass Road and Secondary Parking Lot" Changed the Total Area for Survey Unit 9506-0000 Provide consistency between the LTP and the No from 12,120 to 11,244. associated Release Record.
Changed the Total Area for Survey Unit 9512-0000 Provide consistency between the LTP and the No from 24,181 to 30,701. associated Release Record.
Changed the Total Area for Survey Unit 9514-0000 Provide consistency between the LTP and the No from 26,975 to 18,757. Added "West" to the title associated Release Record. Distinguish the area from Added a New Class 2 Survey Unit 9514-0001, 8,739, the new class 2 area, 9514-0001 Primary Parking Lot East. Characterization data results required a new class 2 survey unit to be formed.
12 2-58, Table Deleted "(Add a Portion of 9518) Info Only" from the No longer necessary. This information is a legacy No 2-10 Survey Area Code Description for Survey Units 9520- clarification from a previous revision.
0001, 0002, & 0003.
Changed the Figure No. for Survey Unit 9520-0003 Reflect the correct revised figure. No from 2-2 to 2-3.
Changed the Figure No. for Survey Unit 9521-0000 Reflect the correct revised figure. No from 2-4 to 2-7.
Page 6 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 13 2-59, Table Changed the Survey Area Code Description for Survey The change is a more appropriate description of the No 2-10 Area 9522 from "Southwest Site Storage Area" to area and promotes consistency between the LTP, FSS "Southeast Site Grounds" Design Documents and Release Records.
Provide consistency between the LTP and the No Changed the Total Area for Survey Unit 9522-0001 from 9870 to 6972 and the Figure No. from 2-4 to 2-2. associated Release Record and reflect the correct revised figure.
Changed the Figure No. for Survey Unit 9522-0002 Reflect the correct revised figure.
from 2-4 to 2-2.
Changed the Figure No. for Survey Unit 9522-0003 Reflect the correct revised figure.
from 2-4 to 2-2.
Changed the Total Area for Survey Unit 9522-0004 Provide consistency between the LTP and the revised Release associated Re. Record and reflect the correct from 1983 to 1386 and the Figure No. from 2-4 to 2-2. revised figure.
Changed the Figure No. for Survey Unit 9522-0005 Reflect the correct revised figure.
from 2-1 to 2-2.
Changed the Figure No. for Survey Unit 9522-0006 Reflect the correct revised figure.
from 2-1 to 2-2.
Changed the Total Area for Survey Unit 9522-0007 Provide consistency between the LTP and the from 1963 to 1952 and the Figure No. from 2-1 to 2-2. associated Release Record and reflect the correct revised figure.
Page 7 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 14 2-60, Table Changed the Figure No. for Survey Unit 9523-0000 Reflect the correct revised figure. No 2-10 from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9524-0000 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9525-0000 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9526-0000 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9526-0001 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9526-0002 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9527-0001 Reflect the correct revised figure. No from 2-4 to 2-7.
Replaced Survey Unit 9527-0002 into Table-2. This survey unit was omitted from Table 2-10 in the No previous revision due to a pagination error.
Page 8 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 15 2-61, Table Changed the Figure No. for Survey Unit 9527-0003 Reflect the correct revised figure. No 2-10 from 2-1 to 2-7.
Changed the Figure No. for Survey Unit 9527-0004 Reflect the correct revised figure. No from 2-1 to 2-7.
Provide consistency between the LTP and the No Changed the Total Area for Survey Unit 9527-0005 from 5680 to 5777 and the Figure No. from 2-1 to 2-2. associated Release Record and reflect the correct revised figure.
Provide consistency between the LTP and the No Changed the Total Area for Survey Unit 9527-0006 from 863 to 790 and the Figure No. from 2-4 to 2-2. associated Release Record and reflect the correct revised figure.
Reflect the correct revised figure. No Changed the Figure No. for Survey Unit 9528-0000 from 2-4 to 2-7.
the Figure No. for Survey Unit 9528-0002 Reflect the correct revised figure. No Changed from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9527-0003 Reflect the correct revised figure. No from 2-4 to 2-7.
16 2-62, Table Changed the Figure No. for Survey Unit 9528-0004 Reflect the correct revised figure. No 2-10 from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9530-0001 Reflect the correct revised figure. No from 2-4 to 2-3; 2-4.
Changed the Figure No. for Survey Unit 9531-0000 Reflect the correct revised figure. No from 2-4 to 2-5.
Changed the Figure No. for Survey Unit 9532 from 2-4 Reflect the correct revised figure. No to 2-7.
Page 9 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 17 2-63, Table Changed the Figure No. for Survey Unit 9535-0001 Reflect the correct revised figure. No 2-10 from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9535-0002 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9536-0000 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9537-0000 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9538-0000 Reflect the correct revised figure. No from 2-4 to 2-7.
Changed the Figure No. for Survey Unit 9539-0001 Reflect the correct revised figure. No from 2-4 to 2-3; 2-4.
Changed the Total Area for Survey Unit 9539-0001 Provide consistency between the LTP and the No from 7236 to 7293. associated Release Record.
Changed the Survey Area Code Description for Survey The change is a more appropriate description of the No Unit 9539-0001 from "North ISFSI Haul Road" to area as there is only one (1) ISFSI Haul Road and "ISFSI Haul Road (Northern Section)" and changed the promotes consistency between the LTP, FSS Design Survey Area Code Description for Survey Unit 9539- Documents and Release Records.
0002 from "South ISFSI Haul Road" to "ISFSI Haul Road (Southern Section)".
Page 10 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 18 2-64, Table Changed the Figure No. for Survey Unit 9801-0000 Reflect the correct revised figure. No 2-10 from 2-9 to 2-6.
Changed the Figure No. for Survey Unit 9802-0000 Reflect the correct revised figure. No from 2-9 to 2-6.
Changed the Figure No. for Survey Unit 9803-0000 Reflect the correct revised figure. No from 2-9 to 2-6.
Changed the Survey Area Code Description for Survey The change is a more appropriate description of the No Area 9804 from "Subsurface soils associated with area and promotes consistency between the LTP, FSS South East Site Grounds" to "Subsurface area Design Documents and Release Records.
associated with Southeast Grounds (Non-Protected Area)"
Provide consistency between the LTP and the No Changed the Total Area for Survey Unit 9804-0000 from 17,973 to 11,568 and the Figure No. from 2-9 to associated Release Record.
2-6.
Changed the Figure No. for Survey Unit 9805-0000 Reflect the correct revised figure. No from 2-9 to 2-6.
Changed the Figure No. for Survey Unit 9806-0000 Reflect the correct revised figure. No from 2-9 to 2-6.
Changed the Figure No. for Survey Unit 9807-0000 Reflect the correct revised figure. No from 2-9 to 2-6.
19 Figure 2-1 Changed the boundaries to show a reduction in the area This change was made in order to facilitate concerns No of Survey Unit 9506-0000 which was added to Survey related to the drainage profiles of the associated areas.
Unit 9514-0000. Both areas are Class 3 survey areas, therefore, FSS Created new class 2 survey unit 9514-0001 from 9514- impact and total encompassed area changes are not a 0000. concern. Characterization data results required a new I _class 2 survey unit be made from 9514-0000.
Page 11 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 20 Figure 2-2 Changed the boundaries to show a reduction in the area Provide consistency between the LTP and the No of Survey Unit 9527-0005 which was added to Survey associated Release Record.
Unit 9527-0006. Added new boundary to separate Created a new class 2 survey unit 9514-0001 from 9514-0000 and 9514-0001. survey unit 9514-0000, a class 3 survey unit.
21 Figure 2-7 Changed the boundaries to show a reduction in the area For the boundary change, this provides consistency No of Survey Area 9528 which was added to new Survey between the LTP and the associated Release Record.
Area 9527 and the renaming of Survey Units 9528- For Survey Areas 9528 to 9527 renaming changes, this 0001 through 0004 to 9527-0001 through 0004. change corrects a previous typo.
Shading was removed from and labeling was added to There is no other map in the LTP which shows the No Survey Area 9521. complete boundary of Survey Area 9521. Labeling was erroneously omitted in the previous revision.
The identification of the on-site portion of Cove Road Labeling was erroneously omitted in the previous No as Survey Area 9525 was added to the map. revision.
22 5-12, Changed "...where planned decommissioning activities Original wording was too prescriptive and precluded No Section are completed..." to "...where planned the commencement of FSS activities in parallel with 5.4.6, decommissioning activities that may cause the spread decommissioning activities where incomplete, but on-Paragraph 1, of contamination in the area of consideration or any going, properly controlled decommissioning activities Sentence 1 adjacent areas are completed or properly controlled..." would have no bearing on the outcome of FSS results.
23 5-20, Table Added Survey Unit 9539-0001 to the table as a survey This survey unit falls within the zone of influence for No 5-3 unit which is affected by existing groundwater existing groundwater monitoring and, therefore, should contamination. be identified as impacted by existing groundwater dose.
24 5-21, Changed "f Future GW is the fraction of the DCGL 25 Add clarification for identification of the applicable No Paragraph mrem/yr dose..." to "f Future GW is the fraction of the DCGL following base case DCGL 25 mrem/yr dose..."
Equation 5-5, Line 3 Page 12 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in
________________________________Commitment 25 5-29, Deleted column for 26" buried piping Unnecessary. There is no 26" buried piping. No Table 5-7 26 5-61, Replaced verbiage to address the exterior surfaces of Replaced additional guidance and clarification which No Section below-grade basements and clarification of the possible was erroneously removed in the previous revision.
5.7.3.1.2.1 methodologies which would be used to assess the condition of such structures._______________________________
27 5-63, Deleted, ". ..to restore the area to grade elevation." The purpose of approximately four (4) feet of backfill No Section is not necessarily to restore the area to grade. While 5.7.3.1.2.2, this may be the case, it is a requirement of the CTDEP Paragraph 5, to have four (4) feet of backfill over any remaining Sentence 2 underground concrete structure.
28 6-7, Section Deleted "the containment liner and" The containment liner was removed and is no longer No 6.3.3, pertinent to the provisions of this paragraph.
Paragraph 1, Sentence 3 29 6-18, Changed "For buildings to remain after release from The application of Building Occupancy Scenario No Section 6.8, the license, the Building Occupancy DCGLs will be DCGLs for release of buildings serves no purpose Paragraph 1, used." to "Presently, the only remaining building after because all site buildings which were released were Sentence 4 license termination will be the Emergency Operations surveyed under the more prescriptive requirements of Facility (EOF) which will be free released in stations procedures. This methodology maintains accordance with applicable station procedures." consistency with that used for all other site buildings
_________________________________________which were free released.
30 6-25, Deleted "As in the case of the containment liner," The containment liner was removed and is no longer No Section pertinent to the provisions of this paragraph.
6.8.2.3, Paragraph 2, Changed "This is conservative approach..." to "This is Correct grammar No Sentence 3 a conservative approach..."
and Sentence 8
Page 13 of 14
Attachment 1 Haddam Neck Plant License Termination Plan, Revision 5 Summary of Changes Item LTP Page Description of Change Reason for Change Downgrade No. or Section in Commitment 31 6-26, Changed "Sections 6.8.2.2 to 6.8.2.3" to "Sections Grammatical correction. No Section 6.8.2.2 and 6.8.2.3".
6.8.2.4, Changed "...buried concrete, containment liner and The containment liner was removed and is no longer Paragraph 1, ... " to "...buried concrete, the in-core instrumentation pertinent to the provisions of this paragraph. This Sentence 1 area steel liner and " change addresses the correct area which may contribute to future groundwater dose.
32 7-2, Section Changed "...April 2000..." to "...April 7, 2000..." Provide a more precise date and to correlate more No 7.2.2, accurately with the cited Reference 7-5.
Paragraph 1, Sentence 1 Page 14 of 14
CY-7-031 Attachment 2 Haddam Neck Plant Update of License Termination Plan Revision 5 Revised Pages February 2007
Haddam Neck Plant License Termination Plan TABLE OF CONTENTS 1 GENERAL INFORMATION 1-1 1.1 Purpose 1-1 1.2 Historical Background 1-1 1.3 Plan Summary 1-2 1.311 General Information 1-3 1.3.2 Site Characterization 1-3 1.3,3 Identification of Remaining Site Dismantlement Activities 1-4 1.314 Site Remediation Plans 1-5 1.3,5 Final Status Survey Plan 1-6 1.316 Compliance with the Radiological Criteria for License Termination 1-7 1.3.7 Update of Site-Specific Decommissioning Costs 1-7 1.3,8 Supplement to the Environmental Report 1-8 1.4 Decommissioning Approach 1-8 1.4,1 Overview 1-8 1.4.2 Phased Release Approach 1-10 1.5 License Termination Plan Change Process 1-12 1.6 References 1-13 2 SITE CHARACTERIZATION 2-1 2.1 Purpose 2-1 2.2 Historical Site Assessment 2-2 2.2,1 Introduction 2-2 2.2,2 Methodology 2-3 2.2,3 Instrumentation Selection, Use and Minimum Detectable Concentration 2-4 2.2,4 Results 2-8 2.2.4.1 Routine Releases 2-8 2.2.4.2 Operational Events 2-8 2.3 Initial Site Characterization 2-15 2.3,1 Introduction 2-15 2.3,2 Methodology 2-16 2.3,3 Site Characterization/HSA Results 2-17 2.3.3.1 Radiological Status 2-17 2.3.3.2 Initial Area Classification 2-48 2.3.3.3 Non-Impacted Area Assessment 2-105 2.3.3.4 Radionuclide Suite Selection 2-106 2.3.3.5 Hazardous Material Status 2-110 2.4 References 2-111 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES 3-1 3.1 Introduction 3-1 3.2 Spent Fuel Pool Island Activities 3-4 February 2007 i Rev. 5
Haddam Neck Plant License Termination Plan 3.3 Completed and Ongoing Decommissioning Activities and Tasks 3-4 3.4 Future Decommissioning Activities and Tasks 3-4 3.5 Radiological Impacts of Decommissioning Activities 3-4 3.5.1 Occupational Exposure 3-5 3.5.2 Radioactive Waste Projections 3-7 3.6 References 3-8 4 SITE REMEDIATION PLANS 4-1 4.1 Introduction 4-1 4.2 Remediation Levels and ALARA Evaluations 4-1 4.2.1 Generic ALARA Screening Levels 4-2 4.2.2 Survey-Unit Specific ALARA Evaluation 4-3 4.2.3 Groundwater ALARA Evaluations 4-4 4.3 Remediation Actions 4-4 4.3.1 Structures 4-4 4.3.2 Soils 4-5 4.3.3 Nonstructural Systems 4-6 4.4 References 4-7 5 FINAL STATUS SURVEY PLAN 5-1 5.1 Introduction 5-1 5.2 Scope 5-1 5.3 Summary of the Final Status Survey Process 5-2 5.4 Survey Planning 5-5 5.4.1 Data Quality Objectives 5-5 5.4.2 Classification of Survey Areas and Units 5-8 5.4.3 Survey Units 5-9 5.4.4 Reference Coordinate Systems 5-10 5.4.5 Reference Areas and Materials 5-11 5.4.6 Area Preparation: Isolation and Control 5-12 5.4.6.1 Structures 5-15 5.4.6.2 Open Land Areas 5-15 5.4.6.3 Excavation Land Areas Resulting from Radiological Remediation 5-15 5.4.6.4 Bedrock 5-16 5.4.6.5 Excavations Resulting from the Removal of Piping Conduit 5-16 5.4.7 Selection of DCGLs 5-16 5.4.7.1 Operational DCGLs 5-17 5.4.7.2 Gross Activity DCGLs 5-22 5.4.7.3 Surrogate Ratio DCGLs 5-23 5.4.7.4 Elevated Measurement Comparison (EMC) DCGLs 5-25 5.4.7.5 Building Basements, Foundations and Footings 5-28 5.4.7.6 Release Limits for Non-Structural Components and Systems 5-28 II Rev. 5 February 2007 2007 ii Rev. 5
Haddam Neck Plant License Termination Plan 5.5 Final Status Survey Design Elements - Surface Soils and Structures 5-31 5.5.1 Selecting the Number of Fixed Measurements and Locations 5-34 5.5.1.1 Establishing Acceptable Decision Error Rates 5-34 5.5.1.2 Determining the Relative Shift 5-35 5.5.1.3 Selecting the Required Number of Measurements for the WRS Test 5-36 5.5.1.4 Selecting the Required Number of Measurements for the Sign Test 5-36 5.5.1.5 Assessing the Need for Additional Measurements in Class 1 Survey Units 5-37 5.5.1.6 Determining Measurement Locations 5-41 5.5.2 Judgmental Assessments 5-42 5.5.3 Data Investigations 5-43 5.5.3.1 Investigation Levels 5-43 5.5.3.2 Investigations 5-44 5.5.3.3 Remediation 5-45 5.5.3.4 Re-classification 5-45 5.5.3.5 Re-survey 5-45 5.6 Survey Protocol for Non-structural Systems and Components 5-46 5.7 Survey Implementation and Data Collection 5-47 5.7.1 Survey Methods 5-48 5.7.1.1 Scanning 5-48 5.7.1.2 Fixed Measurements 5-49 5.7.1.3 Advanced Technologies 5-49 5.7.1.4 Other Advanced Survey Technologies 5-49 5.7.1.5 Samples 5-50 5.7.1.6 Contaminated Concrete Basements 5-50 5.7.2 Survey Instrumentation 5-51 5.7.2.1 Survey Instrument Data Quality Objectives 5-51 5.7.2.2 Instrument Selection 5-52 5.7.2.3 Calibration and Maintenance 5-53 5.7.2.4 Response Checks 5-53 5.7.2.5 MDC Calculations 5-54 5.7.2.6 Typical Instrumentation and MDCs 5-58 5.7.3 Survey Considerations 5-60 5.7.3.1 Survey Considerations for Buildings, Structures and Equipment 5-60 5.7.3.2 Survey Considerations for Outdoor Areas 5-65 5.7.3.3 Surveillance Following Final Status Surveys 5-70 5.8 Survey Data Assessment 5-72 5.8.1 Wilcoxon Rank Sum Test 5-74 5.8.2 Sign Test 5-75 5.8.3 Elevated Measurement Comparison 5-76 5.8.4 Unity Rule 5-77 5.8.5 Data Assessment Conclusions 5-77 5.9 Final Status Survey Reports 5-78 5.9.1 FSS Survey Unit Release Records 5-78 5.9.2 FSS Final Reports 5-79 February 2007 iii Rev. 5
Haddam Neck Plant License Termination Plan 5.10 Quality Assurance and Quality Control Measures 5-80 5.11 References 5-85 6 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE 6-1 TERMINATION 6.1 Site Release Criteria 6-1 6.1.1 Radiological Criteria for Unrestricted Use 6-1 6.1.2 Conditions Satisfying the Site Release Criteria 6-1 6.2 Site Characteristics 6-3 6.3 Dose Modeling Approach 6-5 6.3.1 Overview 6-5 6.3.2 Resident Farmer Scenario 6-6 6.3.3 Building Occupancy Scenario 6-7 6.4 RESidual RADioactivity (RESRAD) and RESRAD-Build Codes 6-8 6.5 Parameter Selection Process 6-9 6.5.1 Classification 6-9 6.5.2 Prioritization 6-9 6.5.3 Treatment 6-10 6.5.4 Sensitivity Analyses 6-10 6.5.5 Parameter Value Assignment 6-11 6.6 DCGLs for Soil 6-11 6.6.1 Dose Model 6-11 6.6.2 Conceptual Model 6-12 6.6.3 Sensitivity Analysis Results 6-12 6.6.4 DCGL Determination 6-13 6.7 DCGLs for Groundwater 6-14 6.7.1 Dose Model 6-14 6.7.2 Conceptual Model 6-14 6.7.3 Sensitivity Analysis Results 6-15 6.7.4 DCGL Determination 6-16 6.8 DCGLs for Concrete 6-18 6.8.1 DCGLs for Concrete: Buildings Standing 6-18 6.8.1.1 Dose Model 6-18 6.8.1.2 Conceptual Model 6-19 6.8.1.3 Sensitivity Analysis Results 6-20 6.8.1.4 DCGL Determination 6-20 February 2007 iv Rev. 5
Haddam Neck Plant License Termination Plan 6.8.2 Future Groundwater Dose Subsurface Structures and Basement /Footings:
Basement Fill Model 6-20 6.8.2.1 General Dose Calculation Model 6-21 6.8.2.2 Future Groundwater Dose Calculation for Basement Concrete 6-24 6.8.2.3 Future Groundwater Dose Calculation for Surface Contamination on Embedded Piping 6-25 6.8.2.4 Summary of All Future Groundwater Dose Calculations 6-26 6.9 Operational DCGLs 6-26 6.10 References 6-27 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS 7-1 7.1 Introduction 7-1 7.2 Decommissioning Cost Estimate 7-2 7.2.1 Cost Estimate Previously Docketed in Accordance with 10 CFR 50.82 and 10 CFR 50.75 Post Shutdown 7-2 7.2.2 Summary of the Site Specific Decommissioning Cost Estimate 7-2 7.2.3. Dismantlement and Decontamination 7-6 7.2.4 Radiological Waste Disposal 7-6 7.2.5 Long-Term Spent Fuel Storage 7-6 7.2.6 Site Restoration and License Termination 7-6 7.3 Decommissioning Funding 7-6 7.4 References 7-8 8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT 8-1 8.1 Introduction 8-1 8.1.1 Overview 8-1 8.1.2 Proposed Site Conditions at the Time of License Termination 8-4 8.1.3 Remaining Dismantlement and Decommissioning Activities 8-4 8.2 Analysis of Site-Specific Issues 8-8 8.2.1 Onsite-Offsite Land Use 8-8 8.2.2 Water Use 8-8 8.2.3 Water Quality 8-9 8.2.4 Air Quality 8-10 8.2.5 Aquatic Ecology 8-12 8.2.6 Terrestrial Ecology 8-12 8.2.7 Threatened and Endangered Species 8-13 8.2.8 Radiological 8-14 8.2.9 Radiological Accidents 8-15 8.2. 10 Occupational Issues 8-16 8.2.11 Socioeconomic Impacts 8-16 February 2007 V Rev. 5
Haddam Neck Plant License Termination Plan 8.2.12 Environmental Justice 8-17 8.2.13 Cultural and Historic Resources Impact 8-18 8.2.14 Aesthetic 8-19 8.2.15 Noise 8-19 8.2.16 Transportation 8-20 8.2.17 Irretrievable Resources 8-20 8.3 References 8-22 APPENDICES Appendix A, Acronym List Appendix B, ALARA Evaluations Appendix C, Financial Materials Appendix D, Input to Sensitivity Analysis (using RESRAD Version 6.1 and RESRAD-Build Version 3.1)
Appendix E, Results of the Sensitivity Analyses (using RESRAD Version 6.1 and RESRAD-Build Version 3.1)
Appendix F, Input to Calculate DCGLs (using RESRAD Version 5.91 and RESRAD-Build Version 2.37)
Appendix G, Calculation of DCGLs (using RESRAD Version 5.91 and RESRAD-Build Version 2.37)
Appendix H Table 2-10, MARSSIM Classifications (Updated as of November 2001) vi Rev. 5 February 2007 2007 vi Rev. 5
Haddam Neck Plant License Termination Plan LIST OF TABLES 1 GENERAL INFORMATION No tables 2 SITE CHARACTERIZATION Table 2-1, Typical Instruments Used at HNP 2-5 Table 2-2, Examples of Unplanned Gaseous Release Events 2-9 Table 2-3, Examples of Unplanned Liquid Release Events 2-12 Table 2-4, Summary of Unrestricted Release Confirmatory Survey Program 2-15 Table 2-5, Radiological Status of HNP Systems 2-19 Table 2-6, Monitoring Well Soil Sample Data 2-34 Table 2-7, Well Water Results 2-35 Table 2-8, Groundwater Level Elevations 2-41 Table 2-9, Temporal Trends in Groundwater Radionuclide Concentrations 2-43 Table 2-10, MARSSIM Classifications 2-53 Table 2-11 A, Nominal Radiological Data Supporting Classifications for Structures 2-65 Table 2-1 1B, Nominal Radiological Data Supporting Classifications for Land Areas 2-99 Table 2-11 C, Nominal Radiological Data Supporting Classifications for Subsurface Areas 2-104 Table 2-12, Radionuclides Potentially Present at HNP 2-106 Table 2-13, Summary of Radionuclide Analysis 2-108 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES Table 3-1, Status of Major HNP Systems, Structures, and Components as of August 2006 3-3 Table 3-2, Radiation Exposure Projections for Decommissioning and Fuel Storage Activities 3-6 Table 3-3, Projected Waste Quantities 3-8 4 SITE REMEDIATION PLANS No tables.
5 FINAL STATUS SURVEY PLAN Table 5-1, HNP Survey Unit Surface Area Limits 5-9 Table 5-2, Typical Media Specific Backgrounds 5-11 Table 5-3, Survey Units Affected by Groundwater Contamination 5-20 Table 5-4, Operational DCGL. Example for Cs-137 5-22 Table 5-5, Area Factors for the Resident Farmer Scenario 5-26 Table 5-6, Area Factors for the Building Occupancy Scenario 5-27 Table 5-7, Release Limits for Buried Piping,dpm/100 cm2 5-29 Table 5-8, Investigation Levels 5-43 Table 5-9, Traditional Scanning Coverage Requirements 5-48 Table 5-10, Volumetric Concrete Sample Requirements 5-51 Table 5-11, Available Instruments and Associated MDCs 5-59 February 2007 vii Rev. 5
Haddam Neck Plant License Termination Plan Table 5-12, Initial Evaluation of Survey Results (Background Reference Area Used) 5-73 Table 5-13, Initial Evaluation of Survey Results (Background Reference Area Not Used) 5-74 6 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION Table 6-1, Base Case DCGLs for Soil 6-13 Table 6-2, Base Case DCGLs for Groundwater 6-18 Table 6-3, Parameter Values for Equations 6-4 and 6-5 6-23 Table 6-4, Concrete Diffusion Coefficients Used in the Basements Fill Model 6-24 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS Table 7-1, Actual and Projected Decommissioning Expenditures 7-5 8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT Table 8-1, Summary of Environmental Impacts from Decommissioning 8-24 Table 8-2, Population Changes in the Vicinity of HNP 8-25 APPENDIX A, ACRONYM LIST No tables.
APPENDIX B, ALARA EVALUATIONS No tables APPENDIX C, FINANCIAL MATERIALS No tables.
APPENDIX D: INPUT TO SENSITIVITY ANALYSIS (USING RESRAD VERSION 6.1 AND RESRAD-BUILD VERSION 3.1)
Table D-1 Input Parameters for Sensitivity Analysis for Soil D-2 Table D-2 Input Parameters for Sensitivity Analysis for Groundwater D-12 Table D-3 Input Parameters for Sensitivity Analysis for Concrete: Buildings D-20 Standing Table D-4 Input Parameters for Sensitivity Analysis for Concrete: Buildings D-23 Demolished February 2007 viii Rev. 5
Haddam Neck Plant License Termination Plan APPENDIX E: RESULTS OF THE SENSITIVITY ANALYSES (USING RESRAD VERSION 6.1 AND RESRAD-BUILD VERSION 3.1)
Table E-1 Results of Sensitivity Analysis and Assignment of Conservative Values for Soil E-2 Table E-2 Results of Sensitivity Analysis and Assignment of Conservative Values for Groundwater E-5 Table E-3 Results of Sensitivity Analysis and Assignment of Conservative Values for Concrete: Buildings Standing E-8 Table E-4 Results of Sensitivity Analysis and Assignment of Conservative Values for Concrete: Buildings Demolished E-10 APPENDIX F: INPUT TO CALCULATE DCGLS (USING RESRAD VERSION 5.91 AND RESRAD-BUILD VERSION 2.37)
Table F-I Input Parameters for Soil DCGLs F-2 Table F-2 Input Parameters for Groundwater DCGLs F-12 Table F-3 Input Parameters for DCGLs for Concrete: Buildings Standing F-20 Table F-4 Input Parameters for DCGLs for Concrete: Buildings Demolished F-25 APPENDIX G: CALCULATION OF DCGLS (USING RESRAD VERSION 5.91 AND RESRAD-BUILD VERSION 2.37)
Table G-1 DCGLs for Soil G-2 Table G-2-1 Determination of Peak Dose Considering Dose Contributions from Progency G-3 Table G-2-2 DCGLs for Groundwater G-6 Table G-3 DCGLs for Concrete: Buildings Standing G-8 Table G-4-1 DCGLs for Concrete: Buildings Demolished G-9 Table G-4-2 Concentration of Residual Radioactive Material in the Contaminated Zone (pCi/g) and the Well Water (RESRAD Groundwater) (pCi/I) and the Equilibrium Groundwater Contamination (pCi/g) G-10 APPENDIX H: TABLE 2-10, MARSSIM CLASSIFICATIONS (UPDATE as of NOVEMBER 2001)
Table 2-10, MARSSIM Classifications H-2 February 2007 ix Rev. 5
Haddam Neck Plant License Termination Plan LIST OF FIGURES (All Figures Are Located at the End of the Associated Section) 1 GENERAL INFORMATION No figures.
2 SITE CHARACTERIZATION Figure 2-1, Survey Unit Boundaries Figure 2-2, Survey Unit Boundaries Figure 2-3, Survey Unit Boundaries Figure 2-4, Survey Unit Boundaries Figure 2-5, Survey Unit Boundaries Figure 2-6, Subsurface Areas Figure 2-7, Survey Unit Boundaries (Phases I through 3) 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES No figures.
4 SITE REMEDIATION PLANS Figure 4-1, Survey Unit ALARA Evaluation Process 5 FINAL STATUS SURVEY PLAN Figure 5-1, Site Grounds Grid Map Figure 5-2, Site Grid Map Figure 5-3, Groundwater Plume Influence Boundary Figure 5-4, Final Status Survey Organization 6 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION Figure 6-1, Site Layout Figure 6-2, Industrial and Peninsula Area Cross Section Figure 6-3, Exposure Pathways Considered in the Resident Farmer Scenario Figure 6-4, Exposure Pathways Considered in the Building Occupancy Scenario Figure 6-5, Parameter Selection Process 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS No figures.
8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT No figures.
February 2007 X Rev. 5
Haddam Neck Plant License Termination Plan LIST OF EFFECTIVE PAGES Front Matter Page Revision Date Table of Contents 5 February 2007 i through x LEP-1 through LEP-3 5 February 2007 I GENERAL INFORMATION Page Revision Date 1-1 through 1-14 4 November 2006 2 SITE CHARACTERIZATION Page Revision Date 2-1 through 2-10 4 November 2006 2-11 through 2-12 5 February 2007 2-13 through 2-15 4 November 2006 2-16 through 2-17 5 February 2007 2-18 through 2-52 4 November 2006 2-53 through 2-64 5 February 2007 2-65 through 2-111 4 November 2006 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES Page Revision Date 3-1 through 3-8 4 November 2006 4 SITE REMEDIATION PLANS Page Revision Date 4-1 through 4-8 4 November 2006 5 FINAL STATUS SURVEY PLAN Page Revision Date 5-1 through 5-11 4 November 2006 5-12 5 February 2007 5-13 through 5-19 4 November 2007 5-20 through5-21 5 February 2007 5-22 through 5-28 4 November 2006 LEP-1 Rev. 5 February 2007 LEP-1I Rev. 5
Haddam Neck Plant License Termination Plan LIST OF EFFECTIVE PAGES 5 FINAL STATUS SURVEY PLAN (Continued)
Page Revision Date 5-29 5 February 2007 5-30 through 5-60 4 November 2006 5-61 through 5-64 5 February 2007 5-65 through 5-89 4 November 2006 6 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION Page Revision Date 6-1 through 6-6 4 November 2006 6-7 5 February 2007 6-8 through 6-17 4 November 2006 6-18 5 February 2007 6-19 through 6-24 4 November 2006 6-25 through 6-26 5 February 2007 6-27 through 6-33 4 November 2006 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS Page Revision D'ate 7-1 4 Novem ber 2006 7-2 5 Febru ary 2007 7-3 through 7-8 4 Novem ber 2006 8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT Page Revision D'ate 8-1 through 8-25 4 Novem ber 2006 Figures Figures 2-1 through 2-2 5 Febru ary 2007 Figures 2-3 through 2-6 4 Octob *er2006 Figure 2-7 5 Febru try 2007 Figure 4-1 4 Novem ber 2006 February 2007 LEP-2 Rev. 5
Haddam Neck Plant License Termination Plan LIST OF EFFECTIVE PAGES Figures 5-1 through 5-4 4 November 2006 Figure 6-1 through 6-5 4 November 2006 Appendix A Page Revision Date A-1 through A-2 0 July 2000 Appendix B Page Revision Date B-I through B-4 I August 2002 Appendix C Page Revision Date C-1 through C-36 0 July 2000 Appendix D Page Revision Date D-1 through D-31 I August 2002 Appendix E Page Revision Date E- 1 through E-12 I August 2002 Appendix F Page Revision Date F1 through F-32 2 August 2002 Appendix G Page Revision Date G I through G-12 I August 2002 Appendix H Page Revision Date H-1 through H-47 2 August 2004 February 2007 LEP-3 Rev. 5
Haddam Neck Plant License Termination Plan The information available at the time of initial classification support classification of the southern unit of the Discharge Canal (from the Canal Road to the river) as a Class 3 area. More recent information (i.e., the 1999 AREOR) reported a concentration of 0.50+/-0.10 pCi/g for Co-60, which is approximately 15% of the Co-60 "base case" soil DCGL. Given the higher potential for residual radioactivity, the entire discharge canal has been reclassified as a Class 2.
This example demonstrates the CYAPCO Survey Area/Unit classification process, which includes a unit reclassification process that drives the most appropriate classification.
In addition to the spills identified above, the HSA identified a number of leaks and unplanned liquid releases that have occurred during the operational lifetime of HNP. The majority of the occurrences were confined to the Radiologically Controlled Area. The leaks and unplanned releases were associated with equipment failures and operational events associated with components within the Containment Building, Primary Auxiliary Building, outside storage tanks, and the radioactive waste processing systems. The most significant unplanned liquid release occurred in 1984, the result of a failure of the reactor cavity seal. Although this event did not result in any release outside of the buildings it is considered the most significant because of the large volume of water involved. This water, released to the basement of containment, was pumped through the purification system to the Refueling Water Storage Tank (RWST). Smears of the seal ring indicated 350 mR/hr gamma, 5.4 rad/hr beta with 120,000 dpm alpha. RWST radiation levels ranged from 65 to 200 mR/hr as a result of relocating water during this period.
Surveys in the basement of Containment on August 23, 1984, indicated contamination levels to 295 mrad/hr beta and 6300 dpm/100 cm2 alpha. Sampling the yard drains concluded that no liquid radioactivity was released to the environment.
Examples of typical events involving radioactive liquid leaks and unplanned releases are presented in Table 2-3. A record of unplanned liquid releases is maintained on site in accordance with the requirements of 10CFR50.75(g) and is identified in the affected area assessment in the Haddam Neck Plant Characterization Report (Reference 2-2) and in the Historical Site Assessment Supplement (Reference 2-3).
The principal impact of these events is to the ground within the Radiologically Controlled Area (RCA). Migration of radioactivity to subsurface soils has occurred in the area of the Primary Auxiliary Building and the Refueling Water Storage Tank, adjacent to the Containment Building.
Radioactivity has also been detected in groundwater wells on site. Assessments of radioactivity in soils and groundwater are further discussed in Sections 2.3.3.1.3 through 2.3.3.1.7.
Radioactive materials from leaks have also impacted the area in the southeast corner of the protected area, a leach field south of the protected area (but within the owner controlled area),
and drain systems leading from the RCA. All of these areas were within the owner controlled area.
2-11 Rev. 5 2007 February 2007 2-11 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-3 Examples of Unplanned Liquid Release Events Date CYAPCO Location of Survey Area Medium Event Reference Event Number Description Document No. (Figs 2-1 through 2-7) 11/1/73 AO-73-11 RWST 9312-0005 Liquid Valve Leak, 270 liters of liquid released to storm drain.
1/28/76 PIR 76-15 "A" Recycle 9312-0005 Liquid 15 gal. of liquid leaked from Test Tank tank to diked area 5/22/76 LER 76-13/990 PAB Below 9312-0006 Liquid Leakage from drain line Drumming below floor Room Floor 2/24/77 LER 77-2 "A" Recycle 9312-0005 Liquid 1000 gal. of radioactive Test Tank water released to diked area around tank.
2/23/79 PIR 79-27 Main Stack 9312-0001 Liquid Manway leakage following SG blowdown rupture disk actuation. 20 gal to yard area.
3/6/79 PIR 79-38 Main Stack 9312-0001 Liquid Manway leakage following SG blowdown rupture disk actuation 3/28/83 PIR 83-37 Septic Tank 9520-0001 Liquid 84 gal. of water from Chem Lab to Septic Tank 8/21/84 PIR 84-136 Containment 9312-0001 Liquid Reactor cavity seal ring Building failure. 200,000 gals of water drained to lower levels of Containment Building 2/24/89 PIR 89-35 Leach Field, 9522, 9312 Liquid 50 gal. release from SFB 115 kV yard floor drain, line discharges to 115 kV yard 9/14/90 PIR 90-239 RWST 9312-0005 Liquid 6 gallon per day leak from RWST identified from inventory monitoring 8/12/91 PIR 91-149 Pipe Trench 9312-0006 Liquid 400 gal. release from open valve to pipe trench 2-12 Rev. 5 February 2007 February 2007 2-12 Rev. 5
Haddam Neck Plant License Termination Plan characterization will continue throughout the decommissioning process, an initial amount of characterization data is necessary to support preparation of the LTP.
The site characterization process focused on data for structures, systems and the site environs, considering radiological, hazardous and state-regulated materials. Groundwater is included in the assessment of the site environs. In addition, activation analyses have been performed on components and structures subjected to neutron flux, to support planning efforts.
The information provided in this section summarizes the characterization of the HNP site. The data is based on surveys, samples and analysis performed through the end of 1999 and is the planning basis for remediation activities, establishment of area classifications, and the development of the Final Status Survey Plan. The figures included in this section depict the plant site at the time of plant shutdown.
2.3.2 Methodology A Data Quality Objective (DQO) approach was applied to the characterization process. This approach focused the effort on gathering sufficient information to achieve the objectives identified in Section 2.1. The site characterization process began with the consolidation of information gathered during the HAS, radiological survey and sample analysis data maintained within the HNP document control program, and current site radiological data maintained by the Radiation Protection Department. This information has been augmented with the results from surveys performed in support of Decommissioning Operations Contractor (DOC) proposal development. The HAS provides the basis for identifying suspect areas outside of those designed to contain radioactivity or those expected to be impacted by normal operations of a nuclear plant.
To facilitate the evaluation of information, available data were sorted by building or structure, and by land areas. A second sort of information was developed based on systems. A unique characterization report was developed for each building or structure with a cross reference to those systems contained within those areas. The characterization process was controlled by site procedures. These procedures established a consistent approach to the evaluation of each area for radiological, hazardous and state-regulated materials that are known to exist or are potential contaminants in structures, systems or soils within that area. The procedural process included the evaluation or determination of:
" the structure or area bounded by the evaluation;
- systems contained within the area, if any;
- HAS identification of events that may have impacted the area;
" area use, present and historic;
" materials of construction;
" presence of radioactive or hazardous material storage areas;
" radiological survey information including extent of area containing radioactivity, radionuclides, exposure rates and contamination levels, both present and historic; and
- potential for migration of contaminants from contiguous areas.
2-16 Rev. 5 February 2007 2007 2-16 Rev. 5
Haddam Neck Plant License Termination Plan The evaluation of each area included a walkdown of the area by a professional experienced in radiological hazards and a second professional experienced in hazardous and state-regulated materials.
Fuel cladding failures occurring during operations, primarily affected the Reactor Coolant System, as well as liquid systems that interfaced with the Reactor Coolant System. As the result of leaks during operation and refueling outage maintenance activities, it is acknowledged that Transuranics (TRUs) may have been released from these systems to surrounding rooms or cubicles. These rooms, cubicles and systems were monitored extensively during outages for personnel protection purposes, and the resulting data obtained from monitoring activities were used to classify them as Class 1. The upper areas of the Containment and Containment dome were initially classified as Class 2. These areas are currently planned for demolition and disposal as radioactive waste.
During the planning of characterization activities, Transuranics activity was considered in survey design by reviewing the operational history and operational surveys of the area. If TRU activity was suspected in an area, proper instruments were selected, smears counted for alpha activity and soil samples analyzed for Am-241, a predominant alpha emitter at the HNP.
Upon completion of the records review and the walkdown of each area, a characterization report for that area was completed. The characterization report for each area contains:
Sa description of the area;
- survey units;
- summary of radiological, hazardous, and state-regulated material conditions within the area;
- classification of the area in accordance with the categories defined by MARSSIM;
- radiologically impacted systems within the area; and
- additional sampling and analysis necessary to support remediation.
The area characterization reports have been compiled in the "Connecticut Yankee Haddam Neck Plant Characterization Report" dated January 6, 2000 (Reference 2-2).
Additional information is provided in the "Haddam Neck Plant Historical Site Assessment Supplement" (Reference 2-3).
2.3.3 Site Characterization/HSA Results 2.3.3.1 Radiological Status 2.3.3.1.1 Systems An extensive review of systems was conducted to determine those systems that contain radioactive materials or in which radioactive material was detected at some time during 2-17 Rev. 5 February 2007 2007 2-17 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications 9106 Discharge Canal 0001 Sediment to Ave. High Water 1 N/A 1,917 N/A 2-2 Level 0002 Sediment to Ave. High Water 2 N/A 5,520 N/A 2-2 Level 2-3 0003 Sediment to Ave. High Water 2 N/A 8,292 N/A 2-3 Level 0004 Sediment to Ave. High Water 2 N/A 9,900 N/A 2-3 Level 0005 Sediment to Ave. High Water 2 N/A 9,632 N/A 2-4 Level 0006 Sediment to Ave. High Water 2 N/A 9,716 N/A 2-4 Level 2-5 0007 Sediment to Ave. High Water 2 N/A 8,692 N/A 2-5 Level February 2007 2-53 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (m2 )
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Unit Area:
Area ode Description Code Code Description Class. Area Area Floor No.
CCode Area) 0008 Sediment to Ave. High Water 2 N/A 9,763 N/A 2-5 Level 0009 Sediment to Ave. High Water 2 N/A 9,933 N/A 2-5 Level 0010 Sediment to Ave. High Water 2 N/A 9,512 N/A 2-5 Level 0011 Sediment to Ave. High Water 2 N/A 6,394 N/A 2-5 Level 0012 Peninsula Wetlands 2 N/A 7,272 N/A 2-4 0013 Peninsula Wetlands 2 N/A 9,011 N/A 2-5 0014 Canal Sediment I N/A 1,870 N/A 2-2 0015 Canal Sediment Within SU 1 N/A 1,170 N/A 2-5 9106-007 February 2007 2-54 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (inm)
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Unit Area:
Area Code Code Description Class. Area Area Floor No.
CCode ode Description Area) 2-2 9302 Northwest Protected Area 0000 Land N/A Land Area N/A 6,410 Grounds 9304 Southwest Protected Area N/A 4,800 N/A 2-2 Grounds 0001 Land Area 0002 Land Area 1 N/A 1,268 N/A 2-2 South Central Protected Area 9306 Grounds 0000 Land Area 2 N/A 4,780 N/A 2-2 9312 Northeast Protected Area Containment Grounds Footprint/DWST 0002 Spent Fuel Bldg Area 1 N/A 1,806 N/A 2-2 0003 Terry Turbine/CST 1 N/A 1,481 N/A 2-2 February 2007 2-55 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (m2
- Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Unit Area:
Area Code Code Description Class. Area Area Floor No.
CCode ode Description Area) 9312 0004 North RCA from EDG Bldg 2-2 Eastward N/A 1,586 N/A 0005 Tank Farm and Resin Facility N/A 1,454 N/A 2-2 0006 PAB Footprint N/A 1,749 N/A 2-2 0007 RRF Bldg/l15kV East 1,566 N/A 2-2 Footprint N/A 0008 11 11k5kV West Side GW etSd W1 N/A 1,348 N/A 2-2 0008 Treatment Facility 0009 East Trench North N/A 1,511 N/A 2-2 East Trench South/MWST N/A 1,365 N/A 2-2 0010 000A&B February 2007 2-56 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (min)
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Area Code Unit Area:
Code Description Code Code Description Class. Area Area Floor No.
Area) 2-2 Land Area 2 N/A 5,850 N/A 9313 Central Site Grounds 0000 Bypass Road and Secondary 9504 Parking lot (Add N. Portion of 0000 Land Area 2 N/A 5,692 N/A 2-1 9502) (info Only)
North Site Grounds (Non-Protected 9506 Area) (Add EOF Parking Area from 0000 Land Area 3 N/A 11,244 N/A 2-1 9510) (Info Only) 9508 Pond 0000 Land Area and Pond 3 N/A 10,831 N/A 2-1 Sediment Northwest Site Grounds (Non-9512 Protected Area) (Remove Truck 0000 Land Area 3 N/A 30,701 N/A 2-1 Monitor and Roadway) (Info Only)
Primary Parking Lot West (Add the 9514 S. Portion of 9502) Add Truck Monitor and Roadway From 9512) 0000 Land Area N/A 18,757 N/A 2-1 (Info Only)
Primary Parking Lot East 0001 Land Area 2 N/A 8,739 N/A 2-1 February 2007 2-57 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (mi)
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Unit Area:
Area Code Code Description Class. Area Area Floor No.
CCode ode Description Area) 2-2 2 N/A 9,870 N/A 9520 Southwest Site Storage Area 0001 Land Area, North Peninsula 2-2 2 N/A 9,845 N/A 2-3 0002 Land Area, North Peninsula 2-3 0003 Land Area, North Peninsula 2 N/A 8,106 N/A 2-3 0004 Land Area, North Peninsula 1 N/A 1,983 N/A 2-3 0005 Land Area, North dPeninsula N/A 1,887 N/A 2-3 9521 Southeast Pond 0000 Land Area and Pond Sediment 3N/A 23,100 N/A 2-7 February 2007 2-58 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (mi2)
Survey Ratio (oa Survey Survey Area unit Survey Unit MARSSIM Floor Total (Total Figure Unit Area:
Area CCode ode Description Code Code Description Class. Area Area Floor No.
Area) 2-2 Land Area N/A 6,972 N/A 9522 Southeast Site Grounds 0001 0002 Land Area 1 N/A 1,913 N/A 2-2 0003 Land Area 150m East of Load N/A 1,997 N/A 2-2 distribution Tower 0004 Land Area 1 N/A 1,386 N/A 2-2 0005 East Side Land of Canal N/A 1,947 N/A 2-2 0006 South RCA Land Area N/A 1,987 N/A 2-2 0007 South RCA Land Area N/A 1,952 N/A 2-2 February 2007 2-59 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (mi)
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Area Code Unit Area:
Code Description Code Code Description Class. Area Area Floor No.
Area) 2-7 9523 Southeast Wetland Area 0000 Land Area 3 N/A 106,000 N/A 9524 South Side Grounds (Non- 0000 Land Area 3 N/A 110,000 N/A 2-7 Protected Area) 9525 Southeast Site Road 0000 Land Area 3 N/A 28,000 N/A 2-7 9526 Northeast Mountain Side 0000 Land Area 3 N/A 44,700 N/A 2-7 0001 Land Area 2 NA 6,536 N/A 2-7 0002 Land Area 2 N/A 6,069 N/A 2-7 9527 East Mountain Side 0001 Land Area 2 N/A 8,600 N/A 2-7 002 Land Area 2 N/A 9,740 N/A 2-7 February 2007 2-60 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (M 2 )
Survey Ratio (oa Survey Survey Area unit Survey Unit MARSSIM Floor Total (Total Figure Unit Area:
Area CCode ode Description Code Code Description Class. Area Area Floor No.
Area) 2-7 0003 Land Area 2 N/A 8,200 N/A 0004 Land Area 2 N/A 5,400 N/A 2-7 0005 Land Area 2 N/A 5,777 N/A 2-2 0006 Land Area 1 N/A 790 N/A 2-2 9528 Southeast Mountain Side 0000 Land Area 3 N/A 575,488 N/A 2-7 0002 Land Area 2 N/A 9,752 N/A 2-7 0003 Land Area 2 N/A 9,447 N/A 2-7 February 2007 2-61 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (M2)
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Area ueyraUnit Area:
Code Code Description Code Code Description Class. Area Area Floor No.
Area) 0004 Land Area 2 N/A 3,058 N/A 2-7 Land Area Bounded by and 9530 Central Peninsula Area 0001 Immediately Adjacent to the 2 N/A 8,000 N/A 2-3 Road 2-4 0002 Western Half of Diked Area and 2 N/A 5,000 N/A 2-4 Immediately Surrounding Sides Eastern Half of Diked Area and 0003 Immediately Surrounding Sides N/A 5,000 N/A 2-4 0004 Open Land Areas 3 N/A 97,000 N/A 2-4 9531 South End of Peninsula 0000 Land Area 3 N/A 118,000 N/A 2-5 9532 East Side Grounds (Non- N/A N/A Non- N/A 375,600 N/A 2-7 Protected Area) impacted February 2007 2-62 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (m2 )
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Unit Area:
Area CCode ode Description Code Code Description Class. Area Area Floor No.
Area) 9535 South East Landfill Area 0001 Land Area 1 N/A 1,900 N/A 2-7 0002 Land Area 2 N/A 3,600 N/A 2-7 9536 Construction Piles Near Rifle 2 N/A 2,200 N/A 2-7 Range 0000 Land Area 9537 Permitted Landfill Area 0000 Land Area 2 N/A 2,200 N/A 2-7 9538 Material Storage Area 0000 Land Area 2 N/A 4,200 N/A 2-7 9539 ISFSI Haul Road 0001 ISFSI Hauleto)2 (Nrhr Road N/A 9,332 N/A 2-3 2-(Northern Section) 2 NA 932 /A 2-4 0002 ISFSI Haul Road N/A 2-4 (Southern Section) 2 N/A 7,239 Februray 2007 2-63 Rev. 5
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (m 2)
Ratio Survey Survey Area Survey Survey Unit MARSSIM Floor Total (Total Figure Area Unit Area:
Code Code Description Code Code Description Class. Area Area Floor No.
Area 9801 Subsurface soils in Radiologically 0000 Subsurface Soil A* N/A 15,788 N/A 2-6 Controlled Area (excluding 9308)
Subsurface soils associated with surface soil survey area 9308 and 9802 subsurface soil areas within the 0000 Subsurface Soil B* N/A 18,292 N/A 2-6 industrial area but outside the radiologically controlled area Subsurface soils associated with 9803 parking lot, Warehouses I & 2, and 0000 Subsurface Soil C* N/A 35,485 N/A 2-6 Steam Generator Mockup Bldg Subsurface area associated with 9804 Southeast Grounds 0000 Subsurface Soil A* N/A 11,568 N/A 2-6 (Non-Protected Area) 9805 Subsurface soils associated with 0000 Subsurface Soil C* N/A 104,207 N/A 2-6 peninsula (excluding area 9531)
Subsurface soils associated with 9806 surface soil portions of survey area 0000 Subsurface Soil A* N/A 4250 N/A 2-6 9535 (South East Landfill) 9807 Subsurface Soils associated with 0000 Subsurface Soil B* N/A 1983 N/A 2-6 9520-0004 February 2007 2-64 Rev. 5
Haddam Neck Plant License Termination Plan Depending on the values of the applicable DCGLs, an alternative method of using material specific backgrounds may be used during final status surveys. This alternative method will involve the determination of the ambient area background in the survey unit and will only be applicable to beta-gamma detecting instruments. This determination will be made prior to performing a final status survey at a location within a survey area that is of sufficient distance (or attenuation) from the surfaces to eliminate beta particles originating from the surface from reaching the detector. At such a location, the ambient background radiation will be due only to ambient gamma radiation and will be a background component of all surface measurements. The average background determined at this location can be used as a conservative estimate since it is expected to be less than the material specific background for the material in the room because it does not fully account for the naturally occurring radioactivity in the materials. Using this lower ambient background will result in conservative calculated residual radioactivity levels. If the average background reading exceeds a predetermined value, the survey would be terminated and an investigation performed to determine and eliminate the reason for the elevated reading. Each of the survey unit readings would subtract this average background value and the Sign Test applied.
Whether or not they are radionuclide specific, all background measurements should account for both spatial variability over the area being assessed and the precision of the instrument or method being used to make the measurements. Thus, the same materials or areas may require more than one background assessment to provide the requisite background information for the various survey instruments or methods expected to be used for final status surveys. The results of these background assessments provides the basis for determining the mean and its associated standard deviation.
5.4.6 Area Preparation: Isolation and Control Before final status survey activities can begin in an area, a transition must occur where planned decommissioning activities that may cause the spread of contamination in the area of consideration or any adjacent areas are completed or properly controlled and the area is subsequently assessed to scope the required isolation and control measures. This includes establishing if the area is ready for final survey activities and identifying any work practice issues that must be addressed in survey planning and design. Determination of readiness for final status survey will be based on characterization and/or remediation surveys indicating that the residual radioactive material is likely to comply with the final status survey criteria.
During and following this assessment, the remediation of an area for the purposes of removal of residual radioactivity, a Remedial Action Survey (RAS) will be performed. This RAS will include scanning and sampling of the areas, as necessary, using appropriate instrumentation to ensure the intended remediation has been accomplished. If no further remediation is required, a turnover survey may be performed as necessary. Data from the RAS may be used for the turnover survey and as input to the design and DQOs for the surface and subsurface FSS.
February 2007 5-12 Rev. 5
Haddam Neck Plant License Termination Plan It is noted, however, that characterization efforts for groundwater contamination are still ongoing and the survey areas to which the HExistingGW term are applied may change. Those changes will be communicated to the NRC. This change may be caused by changes in the location of the plume, detection of groundwater contamination at locations outside the plume or changes to the capture zone or detection of groundwater contamination at locations outside the zone. The Phase 2 Hydrogeologic Work Plan, as described in Section 2.3.1.6, will provide additional characterization of groundwater that will be used to better define the groundwater contamination plume.
Prior to the request to release of any portion of the site from the license, CYAPCO will prepare and make available for inspection a capture zone analysis provided to the NRC in January 2005, based on data collected as part of the Phase 2 Hydrogeological Work Plan, to better define the capture zone distance, Reference 5-13. The "capture zone" is the area surrounding a hypothetical well to be used by the resident farmer, from which existing groundwater contamination could be drawn into the resident farmer's well. The analysis used to determine this area used the hydrogeological conditions and parameters assumed in the Resident farmer Scenario as described in Chapter 6 of the LTP.
Table 5-3 Survey Units Affected by Groundwater Contamination Existing Future Groundwater Groundwater Zone of Influence Concrete 9302 9302 9304-1&2 9304-1&2 9306 9306 9312-1 Thru 10 9312-1 Thru 10 9313 9313 9522-5, 6 & 7 9522-5, 6 & 7 9801 9801 9802 9802 9106-1, 2, 3, 4 & 14 N/A 9512 N/A 9514 N/A 9520-1, 2, 3, 4 & 5 N/A 9521 N/A 9522-1, 2, 3 & 4 N/A 9527-1, 2, 3, 4, 5 & 6 N/A 9528-0, 2 & 3 N/A 9530-1, 2, 3 & 4 N/A 9539-0001 N/A 9803 N/A 9804 N/A 9805 N/A 9807 N/A February 2007 5-20 Rev. 5
Haddam Neck Plant License Termination Plan The compliance formulation for these resident farmer exposure scenarios is re-written as:
(Equation 5-5)
ILP-sil +DCGLP-ExistingGw HFutureGW (i).DCGL + DCGL'aeEisiC + 25 w Base-Soil DCLBase-ExistingGW 2 For simplicity Equation 5-5 may be re-written as:
1 ___Z(f)Lf*o,1 + f~xiEn.gw + ff,,reGW ] (Equation 5-6)
Where, for a given radionuclide i, f. So is the fraction of the total dose from soil.
fI ExistingG~vis the fraction to the total dose from existing contamination in groundwater f FutureGWis the fraction of the base case DCGL 25 mrem/yr dose that is calculated by the Basement Fill Model.
The use of this equation requires that only one variable be unknown. Therefore, values for Future Groundwater dose and f ExisngGW will need to be selected in order to calculate .Soj.
As the building surface operational DCGL are independent of soil and groundwater dose contribution, they will be set based on an ALARA evaluation and/or an administrative dose level at or below 25 mrem/yr.
The following example is provided to illustrate the use of the operational DCGLs for land areas that have the potential for existing and future groundwater dose, with the following assumptions:
- fsil= 0.3 ffExistingGW = 0.2
- Therefore, Future Groundwater Dose (fraction of 25 mremlyr) = 0.5 The above determination will be made prior to the performance of any final status surveys of soils or building surveys in areas where existing groundwater contamination will impact the potential dose. This determination will be provided in the FSS Report or a technical support document and will be applied to the affected survey areas.
The following table provides an example of the building surface operational DCGL for Cs-137 using the fractional values from above.
February 2007 5-21 Rev. 5
Haddam Neck Plant License Termination Plan 1" 2" 2 1/2" 3" 4" 8" 10" 12" 14" 16" 18" 20" 24" Radionuclide H-3 J.30E+03 2.6E+03 3.26E+03 3.91E+03 5.2JE+03 1.04E+04 1.30E+04 1.56E+04 1.82E+04 2.08E+04 2.34E+04 2.61E+04 3.13E+04 C-14 1.94E+04 3.89E+04 4.86E+04 5.83E+04 7.77E+04 1.55E+05 1.94E+05 2.33E+05 2.72E+05 3.11E+05 3.50E+05 3.89E+05 4.66E+05 Mn-54 1.33E+04 2.66E+04 3.32E+04 3.98E+04 5.31E+04 1.06E+05 1.33E+05 1.59E+05 1.86E+05 2.12E+05 2.39E+05 2.66E+05 3.19E+05 Fe-55 1.54E+04 3.09E+04 3.86E+04 4.63E+04 6.17E+04 1.23E+05 1.54E+05 1.85E+05 2.16E+05 2.47E+05 2.78E+05 3.09E+05 3.70E+05 Co-60 8.03E+04 1.61E+05 2.01E+05 2.41 E+05 3.21 E+05 6.42E+05 8.03E+05 9.63E+05 1.12E+06 1.28E+06 1.44E+06 1.61E+06 ! 93E+06 Ni-63 3.80E+04 7.60E+04 9.50E+04 1.14E+05 1.52E+05 3.04E+05 3.80E+05 4.56E+05 5.32E+05 6.08E+05 6.84E+05 7.60E+05 9.12E+05 Sr-90 4.68E+01 9.35E+01 1.17E+02 1.40E+02 1.87E+02 3.74E+02 4.68E+02 5.61E+02 6.55E+02 7.48E+02 8.42E+02 9.35E+02 1.12E+03 Nb-94 3.43E+04 6.85E+04 8.56E+04 1.03E+05 1.37E+05 2.74E+05 3.43E+05 4.I1 E+05 4.80E+05 5.48E+05 6.17E+05 6.85E+05 8&22E+05 Tc-99 6.1OE+03 1.22E+04 1.53E+04 1.83E+04 2.44E+04 4.88E+04 6.1OE+04 7.32E+04 8.54E+04 9.76E+04 1.1OE+05 1.22E+05 1.46E+05 Ag-108m 3.43E+05 6.85E+05 8.56E+05 1.03E+06 1.37E+06 2.74E+06 3.43E+06 4.11 E+06 4.80E+06 5.48E+06 6.17E+06 6.85E+06 8.22E+06 Cs-134 2.09E+04 4.18E+04 5.22E+04 6.26E+04 8.35E+04 1.67E+05 2.09E+05 2.51E+05 2.92E+05 3.34E+05 3.76E+05 4.18E+05 5.01E+05 Cs-137 2.42E+04 4.83E+04 6.04E+04 7.25E+04 9.66E+04 1.93E+05 2.42E+05 2.90E+05 3.38E+05 3.86E+05 4.35E+05 4.83E+05 5.80E+05 Eu-152 6.70E+04 1.34E+05 1.68E+05 2.01E+05 2.68E+05 5.36E+05 6.70E+05 8.04E+05 9.38E+05 1.07E+06 1.21E+06 1.34E+06 1.611E+06 Eu-154 4.68E+04 9.35E+04 1.17E+05 1.40E+05 1.87E+05 3.74E+05 4.68E+05 5.61E+05 6.55E+05 7.48E+05 8.42E+05 9.35E+05 1.12E+06 Eu-155 3.00E+05 6.OOE+05 7.50E+05 9.00E+05 1.20E+06 2.40E+06 3.OOE+06 3.60E+06 4.20E+06 4.80E+06 5.40E+06 6.00E+06 7.20E+06 Pu-238 1.88E+02 3.75E+02 4.69E+02 5.63E+02 7.50E+02 1.50E+03 1.88E+03 2.25E+03 2.63E+03 3.00E+03 3.38E+03 3.75E+03 4.50E+03 Pu-239 1.71 E+02 3.41E+02 4.26E+02 5.12E+02 6.82E+02 1.36E+03 1.711E+03 2.05E+03 2.39E+03 2.73E+03 3.07E+03 3.41E+03 4.09E+03 Pu-241 2.85E+03 5.70E+03 7.13E+03 8.55E+03 1.14E+04 2.28E+04 2.85E+04 3.42E+04 3.99E+04 4.56E+04 5.13E+04 5.70E+04 6.84E+04 Amn-241 8.33E+01 1.67E+02 2.08E+02 2.50E+02 3.33E+02 6.66E+02 8.33E+02 9.99E+02 1.17E+03 1.33E+03 1.50E+03 1.67E+03 2.00E+03 Cm-243 1.155E+02 2.31E+02 2.88E+02 3.46E+02 4.61E+02 9.22E+02 1.1 5E+03 1.38E+03 1.61E+03 1.84E+03 2.07E+03 2.31E+03 2.77E+03 5-29 Rev. 5 February 2007 February 5-29 Rev. 5
Haddam Neck Plant License Termination Plan Part of the planning for the final status survey of a particular survey unit will include an evaluation of the surfaces to be monitored. For conventional instrumentation, surface anomalies will be identified as part of this process and will be taken into account when selecting efficiencies to convert instrument readings to activity and in the calculation of the corresponding MDCs.
Conservative values will be chosen based upon surface conditions. If the condition of the surface in the area changes in a more conservative direction (e.g. shorter detector to surface distance), the effect on the MDC will be assessed but may not be re-derived. If the condition of the surface changes in a non-conservative direction (e.g. different construction material which has higher natural radioactivity) the MDC will be assessed and re-derived.
Expansion joints, stress cracks, floor/wall interfaces, and penetrations into floors and walls for piping, conduit, anchor bolts, etc., are potential sites for accumulation of contamination and pathways for migration into sub-floor soil and hollow wall spaces. Roof surfaces and drainage points are also important survey locations. In some cases, it may be necessary to core, drill, or use other methods as necessary to gain access to areas for sampling.
5.7.3.1.1 Activity Beneath Surfaces Floors, walls, and ceilings of structures may have surface irregularities such as cracks and crevices that require special consideration in the survey process. Such considerations may consist of fixed measurements, longer count times, adjustments to counting efficiencies, sampling of material, or any combinations of these approaches.
Plant areas where residual radioactive material beneath a painted surface is known or suspected to be present will also require special consideration. Sampling will be performed, as appropriate, to confirm or deny the presence of residual activity. If activity is found, the samples should be used to determine both the radionuclides that are present and the density-thickness of the paint layer(s) in order to assess the need for correction factors for counting efficiencies. Such corrections, if required, will be determined following the guidance given in Section 5 of NUREG-1507. The effect of any such corrections on instrument MDCs will be assessed to ensure that measurements can still be performed with the required sensitivity relative to the applicable DCGLs.
5.7.3.1.2 Below-Grade Building Foundations 5.7.3.1.2.1 Basement Exterior surfaces of below-grade basements will be evaluated using the historical site assessment and other pertinent records to determine the potential for sub-surface contamination on these surfaces of below-grade basements. One method available to evaluate the exterior surfaces is the use of core bores through foundation or walls and the taking of soil samples at locations having a high potential for the accumulation and migration of radioactive contamination to sub-surface soils. These biased locations for soil and concrete assessment could include stress cracks, floor and wall interfaces, penetrations through walls and floors for piping, run-off from exterior walls, and leaks or spill in adjacent outside areas, etc. If the soil is found to be free of residual radioactive at the biased locations, it will be assumed that the exterior surface of the foundation is February 2007 5-61 Rev. 5
Haddam Neck Plant License Termination Plan also free of residual activity. Otherwise, additional sampling may be necessary to determine the extent of decontamination and remediation efforts. Another method available for evaluating the exterior surfaces of below-grade foundations is gamma well logging. Soil in biased locations next to the exterior of the buildings may be evaluated using this technique. This technique can provide for rapid isotopic analysis of soils without sampling.
Basement concrete that is to remain will be characterized to determine the extent of any volumetric contamination of the concrete in accordance with Table 5-10. The results will be used in the calculation of the Basement Fill Model.
5.7.3.1.2.2 Footings After completion of final status survey activities of the remaining portions of structures, some concrete may remain in the form of building footings.
There are several building foundations that are to remain. The current approach includes the demolition of the buildings generally to four feet below grade. This will remove ground-level floors and portions of footings and foundation supports. Surfaces of these below-grade structures will be evaluated using the historical site assessment and other pertinent records to determine the potential for sub-surface contamination on the surfaces of the foundations. Soil samples will be taken in the vicinity of the footings/foundation. If the soil is found to be free of residual radioactivity at the biased locations, it will be assumed that the exterior surface of the foundation is also free of residual activity. If soil samples contain residual radioactivity, the exterior surfaces will be sampled or assessed as follows:
These footings will be sampled using concrete sampling (at least 3 samples per footing or group of footings) or assessed using the results of nearby soil samples. The following methodology will be used:
" The average of the soil samples result (for plant-related radionuclides detected) will be calculated for each footing (at least 3 samples per footing or group of footings).
- For Tritium:
o Using the soil distribution coefficient data (Kds) shown in Table F- 1 and equation 6-1 of the LTP, the groundwater concentration in equilibrium with the soil concentrations in the last bullet will be determined.
o Using the concrete distribution coefficients shown in Table F-4 of the LTP and equation 6-1 the concrete concentrations in equilibrium with the groundwater concentrations calculated in the last bullet will be determined.
February 2007 5-62 Rev. 5
Haddam Neck Plant License Termination Plan
- For radionuclides other than H-3:
o At least six pairs of concrete samples with adjacent soil samples will be collected at locations affected by plant leakage and/or groundwater contamination.
o The average and %CV (coefficient of variation) of the ratios of concrete concentrations to soil concentrations will be calculated.
o IF the %CV of the data is less than 25%, the average ratio will be used to determine concrete concentrations from adjacent soil samples.
o If the %CV is 25% or greater, more samples will be taken until a satisfactory variance is calculated or the worst case ratio will be used.
The results of this sampling or assessment will then be used as input to the calculation of future groundwater dose using the basement fill model as discussed in Chapter 6.
The results of sampling and/or assessment of the external surfaces will be used in the design and DQOs of the subsurface FSS to be performed in the area. Following any required remediation approximately 4 feet of backfill soil would be placed over the footings.
The need for a final status survey of the areas with below grade structures will be determined on a graded approach.
For footings and other structures to remain that have a very low or no potential for contamination such as:
" Buildings outside the RCA; and
- Buildings shown by characterization sampling to be free of residual radioactivity; the final status survey will consist of a survey and subsurface FSS of the area including the subsurface structures.
5.7.3.1.3 Sewer Systems, Plumbing Residual radioactivity in sanitary piping or floor drains will be evaluated in the same manner as for non-structural plant systems or components, discussed in Sections 5.4.7.5 and 5.6. Assessment of residual activity levels in piping or floor drains will be via sampling of sediments, fixed measurements, scanning, or a combination of these methods, as appropriate.
All non-RCA sanitary systems at the Haddam Neck Plant drain to on-site leach fields. These systems are independent of other plant systems and all surface water or storm drains. If any residual radioactivity is suspected in portions of the sanitary plumbing systems, evaluations for both the leach fields and the associated system piping may be required. Radiological assessments of piping will be made as described in Section 5.6 of this plan, i.e., by full length surveys of interior surfaces. Evaluations required for any affected leach fields will be made as described in Section 5.7.3.2.2 of this plan, for sub-surface activity. All operable RCA-located systems February 2007 5-63 Rev. 5
Haddam Neck Plant License Termination Plan currently drain to the aerated drains system and are part of the normal plant effluent. Thus, there are no leach fields associated with these systems. During the plant lifetime, toilet facilities, showers and sinks, contained within the RCA, drained to the plant sanitary system and associated leach field. Any piping associated with the systems, which is proposed to remain following decommissioning will be evaluated as described below.
5.7.3.1.4 Ventilation Ducts - Interiors Radiological assessments of ventilation systems will be made by taking measurements at appropriate access points where activity levels should be representative of those on the interior surfaces. Assessments may also be made using in-situ gamma-spectroscopy provided adequate instrument efficiencies and detection limits can be achieved. Exterior surfaces of such systems will be evaluated as part of the building or structure in cases where the system is attached to it or is otherwise an integral component.
5.7.3.1.5 Piping and Embedded Piping The construction of the Haddam Neck Plant was such that there is not expected to be a significant amount of embedded piping to consider in the final survey effort. Most of the radiologically affected piping is in pipe trenches, and thus can be accessed and removed as necessary. Currently approximately 1000 feet of embedded piping is forecasted to remain after Final Status Survey.
Any affected embedded piping remaining at the time of Final Status Survey is expected to be in wall penetrations between areas. Sections of such piping are not expected to be very long (no longer than the wall thickness) and thus should be able to be sampled or surveyed as appropriate to evaluate residual activity levels against the applicable release criteria. The Final Status Survey design of areas containing embedded piping will address this media during the DQO process.
Expected outputs of the DQO process include defining the appropriate type of data to collect; survey measurement processes and survey instrument sensitivity; potential contaminants and appropriate DCGL for the assumed exposure pathway.
5.7.3.1.6 Activated Concrete Although concrete cores have been obtained in Containment, they were not obtained in areas subject to the highest levels of neutron activation. Areas subject to the highest neutron activation are currently inaccessible, and, therefore, specific characterization data is not yet available in all areas. However, neutron activation data from Maine Yankee, Trojan and Yankee Nuclear Power Station indicate that H-3 and Fe-55 are present in the highest concentrations. Other radionuclides such as C-14, Co-60, Eu-152 and Ni-63 are also present. Based upon these data, the activation products Eu- 152 and Eu- 154 were included in the list of radionuclides expected to be present at HNP (Table 2-12).
As the decommissioning progresses and high dose rate components are removed, additional characterization of structures within Containment, including activated concrete and structural components, will take place. These characterization samples will typically be analyzed by gamma spectroscopy with some samples being analyzed for "hard-to-detect" radionuclides.
Therefore, a representative sample of characterization and final status survey samples will be screened for neutron activation.
February 2007 5-64 Rev. 5
Haddam Neck Plant License Termination Plan Internal dose from ingestion of
- Plant foods grown in media containing residual radioactivity and irrigated with water containing residual radioactivity,
- Meat and milk from livestock fed with fodder grown in soil containing residual radioactivity and water containing residual radioactivity,
- Drinking water (containing residual radioactivity) from a well,
- Fish from a pond containing residual radioactivity, and
- Media containing residual radioactivity.
6.3.3 Building Occupancy Scenario Scenario Definition:
The building occupancy scenario, based upon NUREG/CR-5512, Volume 1, was selected to estimate human radiation exposure resulting from residual radioactivity in concrete from standing buildings and building foundations/basements that could reasonable be occupied and to determine corresponding DCGLs. CYAPCO will not leave any basements in place that can be reasonably occupied. These DCGLs are also used to bound residual contamination levels on metal surfaces such as embedded piping to be subsequently used in the calculation of the "future groundwater" dose due to contamination on these metal surfaces.
Critical Group:
Given the fact that the buildings associated with the HNP site are commercial, the average member of the critical group is an adult engaging in light industrial work within the buildings following decommissioning of the site. He/she occupies a commercial facility in a normal manner without deliberately disturbing sources of residual radioactivity. The dose from residual radioactivity in the concrete from the standing building is evaluated for the average member of the critical group as required by 10 CFR Part 20, Subpart E, and described in NUREG -1727, Appendix C.
Exposure Pathways:
The potential exposure pathways, described in NUREG/CR-5512, Volume 1, are depicted on Figure 6-4 and listed below:
- Direct exposure to external radiation from
- Source
- Material deposited on the floor
- Submersion in airborne dust
- Internal dose from inhalation of airborne radionuclides
- Internal dose from inadvertent ingestion of radionuclides from the source February 2007 6-7 Rev. 5
Haddam Neck Plant License Termination Plan Table 6-2 Base Case DCGLs for Groundwater Radionuclide Groundwater DCGL (pCi/I)
H-3 6.52E+05 C-14 9.01E+03 Mn-54 2.42E+04 Fe-55 6.54E+04 Co-60 1.14E+03 Ni-63 3.15E+04 Sr-90 2.51E+02 Nb-94 6.75E+03 Tc-99 2.64E+04 Ag-108m 4.24E+03 Cs-134 3.42E+02 Cs-137 4.31 E+02 Eu-152 7.33E+03 Eu-154 5.05E+03 Eu-155 3.25E+04 Pu-238 1.51E+O1 Pu-239 1.36E+01 Pu-241 4.60E+02 Am-241 1.32E+01 Cm-243 1.94E+01 6.8 DCGLs for Concrete A few of the building basements and footings at HNP will remain in place and be surveyed or assessed for residual radioactivity. Presently CYAPCO's plan is to backfill these partial structures with clean material from off-site or on-site material shown to meet the soil DCGLs once the final status survey or assessment of the structure has been completed. The site dose contribution from these basements will be calculated using the Basement Fill Model as discussed in Section 6.8.2. Presently, the only remaining building after license termination will be the Emergency Operations Facility (EOF) which will be free released in accordance with applicable station procedures.
6.8.1 DCGLs for Concrete: Buildings Standing 6.8.1.1 Dose Model Presently the only building to remain on-site is the Emergency Operations Facility (EOF). The plan is to free release this structure in accordance with current regulations.
The structure is located outside the industrial area at the extreme north boundary of the owner controlled area.
6-18 Rev. 5 February 2007 6-18 Rev. 5
Haddam Neck Plant License Termination Plan Using the parameter values above with equations 6-4 and 6-6, the calculated groundwater concentrations and dose are conservative as a result of the following simplifying assumptions.
- The concrete surfaces are assumed to be represented by a semi-infinite geometry.
" No credit is taken for the barrier to diffusion that the incore instrument area containment liner provides.
- The Brookhaven Study assumes that 2.5 feet of grout (flowable fill) will be placed above the activated concrete region of the In-Core Sump. The depth of grout placed above the activated region will actually be 5 feet, thereby providing additional resistance to transport.
The analysis provided by Reference 6-19 is specifically for the containment and spent fuel pool basements taken together. Other adjacent subsurface structures such as the cable vault portion of the containment and other footings will be inventoried in a similar manner and added to the containment dilution volume footings assessed after completion of the spent fuel pool Basement Fill Model Calculation will be included with the discharge tunnel inventory. This approach will also be used for other basements that remain (i.e. "B" Switchgear and the discharge tunnels) although the released radioactivity from these additional basements will be assumed to migrate and be included with the discharge tunnel inventories.
6.8.2.3 Future Groundwater Dose Calculation for Surface Contamination on Embedded Piping The last source to be evaluated in determining the future groundwater dose from buried structures and components is that resulting for the surface contamination contained on embedded piping to remain after termination of the license.
Embedded piping is that which is present in the containment or spent fuel pool basement and will not be removed or grouted. This source will be included in the calculation of the containment interior groundwater concentration. Surface activity surveys will be performed in accordance with Section 5.4.7.4 using building occupancy DCGLs determined by an ALARA evaluation or administrative limit. Using the radionuclide mix from these and other characterization surveys, each pipe will be assumed to be contaminated to levels equivalent to a total contamination level corresponding to building occupancy DCGL being used. Using this inventory, a CFR value of 1.0 will be used along with the total surface area, and, equations 6-4 and 6-6 will be used to calculate the future groundwater dose and concentrations. These values will be added to their respective values for the concrete case discussed in 6.8.2.2. This is a conservative approach since it assumes:
6-25 Rev. 5 February 2007 6-25 Rev. 5
Haddam Neck Plant License Termination Plan
- 1. that the total inventory of radioactivity for each radionuclide is released to the groundwater/backfill soil system assumed in the containment basement in the first year after release of this area from the NRC license, and
- 2. that all surfaces are contaminated to a level equivalent to the building occupancy DCGL.
6.8.2.4 Summary of All Future Groundwater Dose Calculations Sections 6.8.2.2 and 6.8.2.3 show the method to be used to determine the future groundwater doses due to the individual sources, buried concrete, the in-core instrumentation area steel liner and embedded piping. The individual doses will next be summed to determine the total future groundwater dose from all sources. This calculated dose will be used to supply the "future groundwater" dose component of the compliance equation (5-1). In the case of the containment basement, the future groundwater dose will be calculated as given in the methodology above. This calculation will be performed concurrent with the survey of the containment and be available for NRC review prior to the backfilling of the containment basement.
This approach will also be used for other basements that remain (i.e. "B" Switchgear and the discharge tunnels) although the released radioactivity from these additional basements will be assumed to migrate and be included with the discharge tunnel inventories.
6.9 Operational DCGLs Since additional scenarios, beyond those described above, may be created by combining pathways from different scenarios (e.g., resident farmer with the future groundwater dose calculated using the Basement Fill Model), a method to assess doses from these combined pathways is necessary. Additionally, any initial residual radioactivity in groundwater that exists will also contribute to total dose. For example, a resident farmer may locate his residence and raise crops on soil containing residual radioactivity and use groundwater that is in contact with a buried basement, which may also contain residual radioactivity. Soil and groundwater DCGLs for these combined scenarios along with the future groundwater dose calculated using the Basement Fill Model will be determined on an operational basis, using the base case DCGLs for soil and groundwater and future groundwater dose, calculated in Sections 6.6, 6.7, and 6.8. Section 5.4.7.1 describes, in detail, the methodology to account for all of these contributions.
6-26 Rev. 5 2007 February 2007 6-26 Rev. 5
Haddam Neck Plant License Termination Plan This cost estimate was prepared by Northeast Utilities Service Company (NUSCo) using the TLG Services, Inc., estimating model in accordance with 10 CFR 50.82(a)(8)(iii). The assumed method of decommissioning anticipated a prompt decommissioning technique commonly referred to as DECON. After other revisions to the decommissioning cost estimate as described below, on August 15, 2006, the Company filed a rate settlement with FERC which is pending FERC approval.
7.2 Decommissioning Cost Estimate 7.2.1 Cost Estimate Previously Docketed in Accordance with 10 CFR 50.82 and 10 CFR 50.75 Post Shutdown A letter from CYAPCO to the USNRC dated August 22, 1997 (Reference 7-3) was docketed detailing the PSDAR. This submittal contained a site-specific decommissioning cost estimate. In accordance with 10 FR 50.82(a)(8)(iii), CYAPCO submitted the site-specific decommissioning cost estimate to the USNRC in a letter dated August 25, 1998 (Reference 7-4). The estimate included with the PSDAR had been filed with the FERC prior to docketing. This estimate was the basis for which CYAPCO collected its rates and its anticipated decommissioning expenses. This cost estimate was prepared by NUSCo in 1996 using the TLG model for estimating decommissioning costs.
It was prepared in sufficient detail to identify an activity by activity work breakdown complete with costs for radioactive waste, utility labor, contractor labor, energy, materials and equipment.
In August of 1998, the presiding Administrative Law Judge (ALJ) in the FERC case issued an opinion to the FERC Commissioners that the estimate was "unreliable for rate-making" and recommendations were made identifying appropriate remedies based on the factual data submitted from CYAPCO and intervening parties. CYAPCO prepared a revised cost estimate and engaged in settlement discussion with the certain intervening parties to the rate case. A settlement agreement incorporating the revised decommissioning funding plan was reached in April 2000 and submitted to the FERC for their review and approval. The settlement was approved by the FERC in April 2000.
7.2.2 Summary of the Site Specific Decommissioning Cost Estimate The previous FERC approved decommissioning cost estimate was based on the April 7, 2000 Offer of Settlement between CYAPCO and the Connecticut Department of Public Utility Control and the Connecticut Department of Consumer Counsel (Reference 7-5).
A copy of the FERC-approved Settlement Offer is provided in Appendix C. This FERC-approved decommissioning cost estimate completely replaced and superseded the 1996 cost estimate prepared by Northeast Utilities Service Company using the TLG Services estimating model.
February 2007 7-2 Rev. 5
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CY-07-031 Attachment 3 Haddam Neck Plant License Termination Plan Revision 4 Markup of Affected Pages February 2007
Haddam Neck Plant License Termination Plan TABLE OF CONTENTS 1 GENERAL INFORMATION I-1 1-1 1.1 Purpose 1.2 .Historical Background 1-1 1.3 Plan Summary 1-2 t31
-- F-General-Information 1--3 1-3 1..3.2 Site Characterization 1.3.3 Identification of Remaining'Site Dismantlement Activities 1-4
- 1.3.4 Site Remediation Plans 1-5 1.3.5 Final Status Survey Plan 1-6 1.3.6 Compliance withthe Radiological Criteria for License Termination 1-7 1.3.7 Update of Site-Specific Decommissioning Costs 1-7 1.3.8 Supplement to the Environmental Report 1-8 1.4 Decommissioning Approach 1-8 1.4.1 Overview. 1-8
.1-10.
1.4.2 Phased Release Approach 1.5 License Termination Plan Change*Process 1-12 1.6 References 1-13 2 SITE CHARACTERIZATION 2-1 2.1 Purpose 2-1 2.2 Historical Site Assessment 2-2 2.2.1 Introduction 2-2 2.2:2 Methodology 2-3' 2.2.3 Instrumentation Selection, Use and Minimum Detectable Concentration 2-4 2.2.4 Results 2-8 2.2.4.1 Routine Releases 2-8 2.2.4.2 Operational Events 2-8 2.3 Initial Site Characterization 2-15 2.3.1 Introduction 2-15 2.3.2 Methodology 2-16 2.3.3 Site Characterization/HSA Results 2-17 2.3.3.1 Radiological Status 2-17 2.3.3.2 Initial Area Classification 2-48 2.3.3.3 Non-Impacted Area Assessment 2-105 2.3.3.4 Radionuclide Suite Selection 2-106 2.3.3.5 Hazardous Material Status 2-110 2.4 References 2-111 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES 3-1 3.1 Introduction 3-1 3.2 Spent Fuel Pool Island Activities 3-4 Rev November 2006 i 'oý
ý.4
Haddam Neck Plant License Termination Plan 3.3 Completed and Ongoing Decommissioning Activities and Tasks 3-4 3.4 Future Decommissioning Activities and Tasks 3-4 3.5 Radiological Impacts of Decommissioning Activities 3-4 3.5.1 Occupational Exposure 31-5 3.,5.2. Radioactive Waste Projections *3-7 3.6 References 3-8 4 SITE REMEDIATION PLANS 4-1
-*--4Al---Introducfion- _______ 4-1 __
4.2 Remediation Levels and ALARA Evaluations, 4-1 4.2.1 GGeneric ALARA Screening Levels 4-2 4.2.2 ... Survey-Unit. Specific ALARA Evaluation 4-3.
4.2.3 Groundwater ALARA Evaluations 4-4 4.3 Remediation Actions 4-4 4.3.1 Structures 4-4 4.3.2 Soils ... *-5 4.
4.3.3 Nonstructural Systems 4-6 4.4 References . 4-7 S FINAL STATUS SURVEY PLAN -
5.1 introduction .- 1 5.2 Scope 5-1 5.3 Summary of the Final Status Survey Process 5-2 5.4 Survey Planning 5-5
.5.4.1 Data Quality Objectives 5-5
'5;4.2., Classification of Survey Areas and Units 5-8 5.4.3 Survey Units 5-9 5.4.4 Reference Coordinate Systems 5-10 5.4.5 Reference Areas and Materials 5-11 5.4.6 Area Preparation: Isolation and Control 5-12 5.4.6.1 Structures 5-15 5.4.6.2 Open Land Areas 5-15 5.4.6.3 Excavation Land Areas Resulting from Radiological Remediation 5-15 5.4.6.4 Bedrock 5-16 5.4.6.5 Excavations Resulting from the Removal of Piping Conduit 5-16 5.4.7 Selection of DCGLs 5-16 5.4.7.1 Operational DCGLs 5-17 5.4.7.2 Gross Activity DCGLs 5-22 5.4.7.3 Surrogate Ratio DCGLs 5-23 5.4.7.4 Elevated Measurement Comparison (EMC) DCGLs 5-25 5.4.7.5 Building Basements, Foundations and Footings 5-28 5.4.7.6 Release Limits for Non-Structural Components and Systems 5-28 November 2006 ii 4
Haddam Neck Plant License Termination Plan 5.5- Final Status Survey Design Elements - Surface Soils and Structures 5-31 5.5.1 Selecting the Number of Fixed Measurements and Locations 5-34 5.5.1.1 Establishing Acceptable Decision Error Rates 5-34 5.5.1.2 Determining the Relative 'Shift 5-35 5.5.1.3 Selecting the Required Number of Measurements for the WRS Test 5-36 5.5.1.4 Selecting the Required Number of Measurements for the Sign Test 5-36 5.5.1.5 Assessing the Need for.Additional Measurements in:Class I Survey Units 5-37 5.5.1.6 Determining Measurement Locations 5.5.2 Judgmental Assessments 5-42 5..5.. Data-lnvestigations__ 5-43 5.5.3.1 Investigation Levels 5-43 55.3.2 Investigations 5-44 5.5.3.3 Remediation' 5-45 5.5.3.4 Re-classification 5-45.
-A 5.5.3.5 Re-surv.ey .
5.6 Survey Protocol for Non-structural Systems and Components 5-46 5.7 Surveylmplementation and Data Collection *5-47 5.71- Survey Methods 5-48 5.7.1.1.. Scanning.9 5-48, 5.7.1.2 Fixed Measurements 5-49 5.7.1.3 Advanced Technologies 5-49 5.7.1.4., Other Advanced Survey Technologies 5-49 5.7.1.5 Samples 5-50 5.7.1.6 Contaminated Concrete Basements 5-50
.5.7.2: Survey Instrumentation 5-:51 5.7.211 . Survey Instrument Data Quality Objectives *5-51 5.7..2.2 Instrument Selection 5-52 5.7.2.3 Calibration and Maintenance 5-.53 5.7.2.4 Response Checks .5-53.
5.7.2.5 MDC Calculations 5-54 5.7.2.6 Typical Instrumentation and MDCs 5-58 5.7.3 Survey Considerations 5-60 5.7.3.1 Survey Considerations for Buildings, Structures and Equipment 5-60 5.7.3.2 Survey Considerations for Outdoor Areas 5-65 5.7.3.3 Surveillance Following Final Status Surveys 5-70 5.8 Survey Data Assessment 5-72 5.8.1 Wilcoxon Rank Sum Test 5-74 5.8.2 Sign Test 5-75 5.8.3 Elevated Measurement Comparison 5-76 5.8.4 Unity Rule 5-77 5.8.5 Data Assessment Conclusions 5-77 5.9 Final Status Survey Reports 5-78 5.9.1 FSS Survey Unit Release Records --78 5.9.2 FSS Final Reports November 2006 2006 iii
.°i
-IF)6 Rev.
Haddam Neck Plant License Termination Plan 5.10 Quality Assurance and Quality Control Measures 5-80 5.11 References 5-85 6 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE 6-1 TERMINATION.
6.1 Site Release Criteria 6-1 6.1.1 Radiological Criteria for.Unrestricted Use 6-1 6.1.2 Conditions Satisfying the Site Release Criteria 6-1 6.2 Site Characteristics* . __ * *.- 6-3 6.3 Dose Modeling Approach 6-5
.6.3.1. Overview. 6-5 6.3.2 Resident Farmer Scenario 6-6 6.3.3 Building Occupancy Scenario 6-7 6.4 RESidual RADioactivity (RESRAD) and.RESRAD-Build Codes . 6-8 6.5 Parameter Selection Process 6-9 6.5.1 Classification 6-9 6.5.2 Prioritization. 6-9 6.5.3 Treatment 6-10 6.5.4 Sensitivity Analyses. 6-10 6.5.5 "ParameterfValueAssignment. 6-11 6.6 DCGLs for Soil 6-11 6.6.1 Dose Model 6-11 6.6.2 Conceptual Model 6-12
.'6.6.3 Sensitivity Analysis Results 6-12 6.6.4 DCGL Determination 6-13 6.7 DCGLs for Groundwater 6-14 6.7.1 Dose Model 6-14 6.7.2 Conceptual Model 6-14 6.7.3 Sensitivity Analysis Results 6-15 i.p 6.7.4 DCGL Determination 6.8 DCGLs for Concrete 6-18 6.8.1 DCGLs for Concrete: Buildings Standing 6-18 6.8.1.1 Dose Model 6-18 6.8.1.2 Conceptual Model 6-19 6.8.1.3 Sensitivity Analysis Results 6-20 6.8.1.4 DCGL Determination 6-20 November 2006 iv Re
Haddam Neck Plant License Termination Plan 6.8.2 Future Groundwater Dose Subsurface Structures and Basement /Footings:
Basement Fill Model 6-20 6.8.2.1 General Dose Calculation Model 6-21 6.8.2.2 Future Groundwater Dose Calculation for Basement Concrete 6-24 6.8.2.3 Future Groundwater Dose Calculation for Surface Contamination on Embedded Piping.. 6-25 6.8.2.4 Summary of All Future Groundwater Dose Calculations 6-26 6.9 Operational DCGLs 6-26
-6.1.0References . 6-27 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONIN.G COSTS 7A1 7.1 Introduction. 7.-1 7.2 Decommissioning Cost Estimate. 7-2 7.2.1 Cost E"stimate Previously Doketed Inc'A.' dnewt.. .
and 10 CFR 50.75 Post Shutdown 7-2 7.2.2 Summary of the Site Specific Decommissioning Cost Estimate 7-2 7.2.3' Dismantlement and Decontamination 7-6 7.2.4 Radiological Waste Disposal: "7-6 7.2.5 Long-Term Spent Fuel Storage 7-6.
7.2.6..Site Restoration and License Termination 7-6 7.3 Decommissioning Funding. 7-6 7.4 References 7-8 8 SUPPLEMENT. TO TIM ENVIRONMENTAL REPORT 8-1 8.1 Introduction 8-1 8.1.1 Overview 8-1 8.1.2 Proposed Site Conditions at the Time of License Termination 8-4 8.1.3 Remaining Dismantlement and Decommissioning Activities 8-4 8.2 Analysis of Site-Specific Issues 8-8 8.2.1 Onsite-Offsite Land Use 8-8 8.2.2 Water Use 8-8 8.2.3 Water Quality 8-9 8.2.4 Air Quality 8-10 8.2.5 Aquatic Ecology 8-12 8.2.6 Terrestrial Ecology 8-12 8.2.7 Threatened and Endangered Species 8-13 8.2.8 Radiological 8-14 8.2.9 Radiological Accidents 8-15 8.2.10 Occupational Issues 8-16 8.2.11 Socioeconomic Impacts 8-16 November 2006 v
Haddam Neck Plant License Termination Plan 8.2.12 Environmental. Justice 8-17 8.2.13 Cultural and Historic Resources Impact 8-i 8 8.2.14 Aesthetic 8-19 8.2.15 Noise. 8-19 8.2.16 Transportation 8-20 8.2.17 Irretrievable Resources 8-20 83 fer-eneces . 2-2 APPENDICES Appendix A, Acronym List Appendix B, ALARA Evaluations Appendix C, FinancialMaterials Appendix D, Input to Sensitivity Analysis (using RESRAD Version 6.1 and RESPRAD-Build Version3.)
Appendix E, Results ofthe Sensitivity Analyses (using RESRAD Version 6.1 and RESRAD-Build.
Version 3.1)
Appendix F, Input to Calculate DCGLs (using RESRAD Version 5.91 and RESRAD-Build Version 2.37)
Appendix G, Calculation of DCGLs (using RESRAD Version 5.91 and RESRAD-Build Version 2.37)
Appendix H Table 2-10, NMARSSLM Classifications (Updated as of November 2001)
November 2006 VI vi f 4S
~eý
Haddam Neck Plant License Termination Plan LIST OF TABLES I GENERAL INFORMATION No tables 2 SITE CHARACTERIZATION.
Table 2-1, Typical instruments Used at HNP2-5 Table 2-2, Examples of Unplanned Gaseous Release Events 2-9 Table-2-3, Examnples-of-Unplanned-Liquid-Release-Events- -1 Table 2-4, Summary of Unrestricted Release Confirmatory Survey Program 2-15 Table 2-5, Radiological Status of HNP Systems 2-19 Table 2-6, Monitoring Well Soil Sample Data 2-34 Table 2-7, Well Water Results. 2-35 Table 2-8, Groundwater Level Elevations ')A1 Table 2-9, Temporal Trends in Groundwater Radionuclide Concentrations 2-43 Table 2-10, MARSSIM Classifications 2753 Table 2-1 IA, Nominal Radiological Data Supporting Classifications for Structures .2-65 Table 2-1 1B. Nominal Radiological Data Supporting Classifications for Land Areas 2-99 Table. 2-11 C Nominal Radiological Data Supporting Classifications for Subsurface Areas 2-104 Table 2-12, RadionuclidesPotentially Present at I-NP 2-106 Table;2-13, Summary of RadionuclideAnalysis 2-108 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES Table 3-I,, Status of Major lNP Systems, Structures, and Components as of August 2006 3-3 Table 3-2, Radiation Exposure Projections for Decommissioning and Fuel Storage Activities 3-6 "Table 3-3, Projected Waste Quantities 3-8 4 SITE REMEDIATION PLANS No tables.
5 FINAL STATUS SURVEY PLAN Table 5-1, HNP Survey Unit Surface Area Limits 5-9 Table 5-2, Typical Media Specific Backgrounds 5-11 Table 5-3, Survey Units Affected by Groundwater Contamination 5-20 Table 5-4, Operational DCGL. Example for Cs-137 5-22 Table 5-5, Area Factors for the Resident Farmer Scenario 5-26 Table 5-6, Area Factors for the Building Occupancy Scenario 5-27 Table 5-7, Release Limits for Buried Piping,dpm/l 00 cm 2 5-29 Table 5-8, Investigation Levels 5-43 Table 5-9, Traditional Scanning Coverage Requirements 5-48 Table 5-10, Volumetric Concrete Sample Requirements 5-51 Table 5-11, Available Instruments and Associated MDCs 5-59 November 2006 vii Rev.* 4
Haddam Neck Plant License Termination Plan Table 5-12. Initia'l Evaluation of Survey 'Results (Background Reference Area Used) 5-73 Table 5-1 3. Initial Evaluation of Survey Results (Background Reference Area Not Used) 5-74 6 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION Table 6-1. Base Case DCGLs for Soil 6-13 Table 6-2. Base Case DCGLs for Groundwater 6-18 Table 6-3, Parameter Values for Equations 6-4 and 6-5 6-23 Table 6-4. Concrete Diffusion Coefficients Used in the Basements Fill Model 6-24 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS Table 7-1, Actual and Projected Decommissioning Expenditures 7-5 8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT Table 8-1, summary of Environmental Impacts from Decommissioning 8-24 Table 8-2, Population Changes in the Vicinity of HNP 8-25 APPENDIX A, ACRONYM LIST No tables.
APPENDIX B, ALARA EVALUATIONS No tables APPENDIX C, FINANCIAL MATERIALS No tables.
APPENDIX D: INPUT TO SENSITIVITY ANALYSIS (USING RESRAD VERSION 6.1 AND RESRAD-BUILD VERSION 3.1)
Table D-1 Input Parameters for Sensitivity Analysis for Soil] )-2 Table D-2 Input Parameters for Sensitivity Analysis for Groundwater [ 9-12 Table D-3 Input Parameters for Sensitivity Analysis for Concrete: Buildings [ )-20 Standing Table D-4 Input Parameters for Sensitivity Analysis for Concrete: Buildings I)-23 Demolished viii November 2006 2006 viii ýfR~ev6
Haddam Neck Plant License Termination Plan APPENDIX E: RESULTS OF THE SENSITIVITY ANALYSES (USING RESRAD VERSION 6.1 AND RESRAD-BUILD VERSION 3.1)
Table E- I Results of Sensitivity Analysis and Assignment of Conservative Values for Soil E-2 Table E-2 Results of Sensitivity Analysis and Assignment of Conservative Values for Groundwater E-5 Table E-3 Results of Sensitivity Analysis and Assignment of Conservative Values for Concr.ete: Buildings Standing E-8 Table E-4 Results of Sensitivity Analysis and Assignment
. of-Conservative-Values-for-Concrete:-Buildings-Demolished- -E--0 APPENDIX F: INPUT-TO CALCULATE DCGLS (USING RESRAD VERSION 5.91 AND RESRAD-BUILD VERSION 2.37)
Table F-I Input Parameters for Soil DCGLs F-2 Table F-2 Input Parameters for Groundwater DCGLs F-12 Table F-3 Input Parameters for DCGLs.for Concrete: Buildings Standing F-20 Table F-4 InputParameters for DCGLs for Concrete: Buildings Demolished F-2 5 APPENDIX G: CALCULATION OF DCGLS (USING RESRAD VERSION 5.91 AND RESRAD-BUILD VERSION. 2.37)
Table G-l DCGLs for Soil G-2 Table G-2-1 Determination of Peak Dose Considering Dose Contributions from Progency :. G-3 Table G-2-2 DCGLs for Groundwater G-6.
Table G-3 DCGLs for Concrete: Buildings Standing G-8 Table G-4-1 DCGLs for Concrete: Buildings Demolished G-9 Table G-4-2 Concentration of Residual Radioactive Material in the Contaminated Zone (pCi/g) and the Well Water (RESRAD Groundwater) (pCi/I) and the Equilibrium Groundwater Contamination (pCi/g) G-1 0 APPENDIX H: TABLE 2-10, MARSSIM CLASSIFICATIONS (UPDATE as of NOVEMBER 2001)
Table 2-10, MARSSIM Classifications H-2 November 2006 ix Rev. 4
Haddam Neck Plant License Termination Plan LIST OF FIGURES (All Figures Are. Located at the End of the Associated Section)
I GENERAL INFORMATION No figures.
2 SITE CHARACTERIZATION Figure 2-1. Survey Unit Boundaries Figure 2-2, Survey Unit Boundaries
- -Fig*r- 2-3_SiSrwheUfit-iBoundaries Figure 2-4. Survey Unit Boundaries Figure 2-5, Survey Unit Boundaries,
.:Figure 2-6. Subsurface Areas Figure 2-7, Survey.Unit Boundaries (Ph*ses I through 3) 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES No figures.
4 SITE REMVIEDIATION PLANS Figure 41, Survey Unit ALAR Evaluation Process 5 FINAL STATUS SURVEY PLAN Figure 5-1, Site Grounds Grid Map Figure 5-2, Site Grid Map Figure 5-3, Groundwater Plume Influence Boundary Figure 5-4, Final Status Survey Organization 6 COM[PLIANCE WITH THE RADIOLOGICAL CPITEPRA FOR LICENSE TERMINATION Figure 6-1, Site Layout Figure 6-2, Industrial and Peninsula Area Cross Section Figure 6-3, Exposure Pathways Considered in the Resident Farmer Scenario Figure 6-4, Exposure Pathways Considered in the Building Occupancy Scenario Figure 6-5, Parameter Selection Process 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS No figures.
8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT No figures.
x Rev.4 November November 2006 x 19 J.4
Haddam Neck Plant License Termination Plan LIST OF EFFECTIVE PAGES Front Matter Page Revision Date.
1- through 1-144 " "ovember 2006 2 SITE CHARACTERIZATION a ....
...... Revision 3 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES Page Revision Date 3-1 through 3-8 4 November 2006 4 SITE REMEDIATION PLANS Page Revision Date 4-1 throuý 'J-9 4 November 2006 5 FINAL STATUS SURVEY PLAN Pae te-u8sion Da e 2 LEP-1 Rev. 4 November 2006 LEP-1 Rev. 4
Haddam Neck Plant License Termination Plan LIST OF EFFECTIVE PAGES 6 COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION 7 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS.
.*.....;.' . * -.. Revision 8 SUPPEMN OT 4.
EN.IROMENTA REPORT 8 SUPPLEMENT TO THE ENVIRONMENTAL REPORT Page Revision. Date 8-.1 through 8-25 4 November 2006 Figures V Fi ures 2-1 through 2-7 4 Novernber 2006 fFigure4-1 Novem ber 2006..
.Figures 5-1 through 5-4 4 November 2006 Figure 6-1 through 6-5 4 November 2006 Appendix A Page Revision Date A-I through A-2 0 July 2000 Appendix B Page Revision Date B-1 through B-4 I August 2002 LEP-2 Rev. 4 November 2006 LEP-2 Rev. 4
Haddam Neck Plant License Termination Plan The information available at the time of initial classification support classification of the southern unit of the Discharge Canal (from the Canal Ro'ad to the river) as a Class 3 area. More recent information (i.e., the 1999 AREOR) reported a concentration of 0.50+/-0.10 pCi/g for Co-60, which is approximately 15% of the Co-60 "base case" soil DCGL. Given the higher potential. for residual radioactivity, the entire discharge canal has been reclassified as a Class 2.
This example demonstrates-the CYAPCO Survey Area/Unit classification process, which includes a unit reclassification process that drives the most appropriate classification.
-In addition-to-the-spl-lsidentified-above,itheHSA-identifiejd-a number of leaks and unplanned liquid releases that have occurred during the.operational lifetime of H-NP. The majority of the occurrences. were confined to the Radiologically Controlled Area. The leaks and -unplanned releases were associatedmwith equipment failures and. operational events associated with components within the Containment Building, PrimaryAuxiliary Building, outside storage tanks, and the radioactive waste processing systems. The most significant unplanned liquid release occurred in 1984, the result of a failure of the reactor cavity seal. Although this event did not result in any. release outside of the buildings it is considered the most sinni.ficant because of the large volume of water involved. This water, released to the basement of containment, was.
pumped through the purification system .to the Refueling Water Storage Tank (RWST). Smears of the seal ring indicated 350 mR/hr gamma, 5.4 rad/hr beta with.120,000 dpm alpha. RWST.
radiation levels ranged from 65 to .200 mR/hr as a result of relocating water during this period.
Surveys in the basement of Containment on August 23,)1984 indicated.contamination levels to 295 mrad/hr beta arnd 6300 dpmi/100 cm 2 alpha. Smpling[he yard drains concluded that no liquid radioactivity was released to the environment.
Examples of typical events involving radioactive liquid leaks and unplanned releases are presented in Table 2-3. A record of unplanned liquid releases is maintained on site in accordance with the requirements of 1.OCFR50.75(g) and is identified in the affected area assessment in the Haddam Neck Plant Characterization Report (Reference 2-2) and in the Historical Site Assessment Supplement (Reference 2-3).
The principal impact of these events is to the ground within the Radiologically Controlled Area (RCA). Migration of radioactivity to subsurface soils has occurred in the area of the Primary Auxiliary Building and the Refueling Water Storage Tank, adjacent to the Containment Building.
Radioactivity has also been detected in groundwater wells on site. Assessments of radioactivity in soils and groundwater are further discussed in Sections 2.3.3.1.3 through 2.3.3.1.7.
Radioactive materials from leaks have also impacted the area in the southeast comer of the protected area, a leach field south of the protected area (but within the owner controlled area),
and drain systems leading from the RCA. All of these areas were within the owner controlled area.
November 2006 2-11 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-3 Examples of Unplanned Liquid Release Events Date CYAPCO Location of Survey Area Medium Event Reference Event Number Description Document No. .(Figs 2-1 _ "
- through 2Q6) i 1/1/73 AO-73-1 I RWST 9312-0005" Liquid Valve Leak, 270liters of liquid released to storm
_drain..
1/28/76 PIER 76-15. "A" Recycle 931.2-0005 Liquid 15 gal. of liquid leaked from
.... ____Test Tank tank to diked area 5/22/76 LER 76-13/990 PAB Below 9312ý0006 Liquid . Leakage from drain line Drumming below floor Room Floor "_ __
2/24/77 LER 77-2 "A" Recycle 9312-0005 Liquid 1000 gal. of radioactive Test Tank water released to diked area around tank.
2/23/79 PIR 79-27 Main Stack " 9312-0001 Liquid Manway leakage following SG blowdown rupture disk actuation. 20 gal to yard
_ _"__.__* .. __ . _ ... area.
3/6/79 PIE 79-38 Main Stack 9312-0001. Liquid. Manway leakage following'SG blowdown
_,_______"rupture disk actuation 3/28/83 PIE 83-37 Septic Tank 9520-0001 Liquid 84 gal. of water from Chem Lab to Septic Tank 8/21/84 PIE 84-136 Containment 9312-0001 Liquid Reactor cavity seal ring Building . .. failure. 200,000 gals of.
water drained to lower levels of Containment Building 2/24/89 PIE 89-35 Leach Field, 9522, 9312 Liquid 50 gal. release from SFB 115 kV yard floor drain, line discharges to 115 kV yard 9/14/90 PIE 90-239 RWST 9312-0005 Liquid 6 gallon per day leak from RWST identified from inventory monitoring 8/12/91 PIR 91-149 Pipe Trench 9312-0006 Liquid 400 gal. release from open valve to pipe trench 2-12 Rev. 4 November 2006 2-12 Rev. 4
Haddam Neck Plant License Termination Plan characterization will continue throughout the decommissioning process, an initial amount of characterization data is necessary to support preparation of the LTP.
The site characterization process focused on data for structures, systems and the site environs, considering radiological, hazardous and state-regulated materials. Groundwater is included in the assessment of the site environs. In addition, activation analyses have been performed on components and structures subjected to neutron flux, to support planning efforts.
,The information provided in this section summarizes the characterization of the HNP site. The data is
-based-on-surveys,- samples-and-anal-ysis-perlformed-throughthe-endof1 9-99_and is the planning basis for remediation activities, establishmentlof area classifications, and the development of the Final Status Survey Plan. The figures included in this section depict the plant site at the time of plant shutdown.
Sethodo.ogy.
A Data Quality Objective (DQO) approach was applied to the characterization process. This approach focused the effort on gathering sufficient information to achieve the objectives identified in Section 2.1. The site characterization process began with the consolidation of information gathered during the HSA, radiological survey and sample analysis data maintained within the. HNP document control program, and current site radiological data maintained by the Radiation Protection.Department. This information has been .augmented with theresults from surveys performed.in support of.Decoirimissioning Operations Contractor.(DOC) popsal development. The :USA provides the basis .for identifying suspeci areas outside of those designed to contain radioactivity or those expected to be impacted by normal operations of a nuclear plant.
To facilitate the evaluation of information, available data were sorted by building or structure, and by land areas. A second sort of information was developed based on systems. A unique characterization report was developed for each building or structure with a cross reference to those systems contained within those areas. The characterization process was controlled by site procedures. These procedures established a consistent approach to the evaluation of each area for radiological, hazardous and state-regulated materials that are known to exist or are potential contaminants in structures, systems or soils within that area. The procedural process included the evaluation or determination of:
- the structure or area bounded by the evaluation;
- systems contained within the area, if any;
- HSA identification of events that may have impacted the area;
- area use, present and historic;
- materials of construction;
- presence of radioactive or hazardous material storage areas;
- radiological survey information including extent of area containing radioactivity, radionuclides, exposure rates and contamination levels, both present and historic; and
- potential for migration of contaminants from contiguous areas.
2-16 Rev. 4 November 2006 2-16 Rev. 4
Haddam Neck Plant License Termination Plan The evaluation of each area included a walkdown of the area by. a professional experienced in radiological hazards and a second professional experienced in hazardous and state-regulated materials.
Fuel cladding failures occurring during operations, primarily affected the Reactor Coolant
- System, as well. as liquid systems that interfaced with the Reactor Coolant System. As the result of leaks during operation and refueling outage maintenance activities, it is acknowledged that Transuranics (TRUs) may have been released from these systems to surrounding rooms or
-cubicles.*-hese-rooms,-cubicles-and-systems were monitored extensively during outages for personnel protection purposes, and the resulting data obtained from.monitoring activities were used to classify. them as Class 1. The upper areas of the Containment and Containment dome were initially classified as Class 2. These areas are currently planned -fordemolition and disposal as radioactive waste.
During the planning of characterization activities, Transuranics activity was considered in survey design by reviewing the operational history and operational surveys of the area. If TRU activity was suspected in an area, proper instruments were selected, smears counted for alpha activity and soil samples analyzed for Am-241, a predominant alpha emitter at the HNP.
Upon completion of thexrecords review and the walkdown of each area, a characterization report for that area was c6mpleted. The characterization report for each area contains:
- a description of the area;
- survey units;
" summary of radiological, hazardous, and state-regulated material conditions within the area; o classification of the area in accordance with the categories defined by MARSSIM;
" radiologically impacted systems within the area; and
- additional sampling and analysis necessary to support remediation.
The area characterization reports have been compiled in the "Connecticut Yankee Haddam Neck Plant Characterization Report" dated January 6, 2000 (Reference 2-2).
Additional information is provided in the "Haddam Neck Plant Historical Site Assessment Supplement" (Reference 2-3).
Site Characterization/HSA Results ).5 2.3.3.1 Radiological Status 2.3.3.1.1 Systems An extensive review of systems was conducted to determine those systems that contain radioactive materials or in which radioactive material was detected at some time during November 2006 2-17 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Areal(m 2)
I Ratio reSurvey AraUnit Area Suiey Survey Unit MARSSIM
.. Floor I Total . (Total Area: Figure Code Description Code Code Descriptionw, Class. Area 11 Area Floor No.
. _ _...._ __ Area) 9106 Discharge Canal 0001 Sediment to Ave. High Water I N/A 1,917 N/A Level ,2 0002 Sediment to Ave. High Water 2 N/A 15,520 N/A Level 0003 Sediment to Ave. High Water 2 N/A 8,292 N/A Level 0004 Sedimentto Ave. High Water 2 N/A 9,900 N/A Level 0005 Sediment to Ave. High Water 2 N/A 19,632 N/A 2-4 Level .
0006 Sediment to Ave. High Water 2 N/A 19,716. N/A 24 Level 0007 Sediment to Ave. High Water 2 N/A 8,692 N/A I,
Level tI November 2006 2-53. Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area Srea l(in )
Ratio rey SrereSuvyArea Survey Area urvey Unit Survey Unit MARSSIM Floor Total (Total Toa.Area: Figure C ode Code Description C od e ". Code Description
.. Class.
"Floor Area. !Area* No.
Area) 0008 Sediment to Ave. High Water 2 N/A 9,763 N/A Level 0009 Sediment to Ave. High Water 2 N/A 9,933 N/A Level .
0010 Sediment to Ave. High Water 2 NIA 9,512 N/A Level 0011 Sediment to Ave. High Water 2 N/A 6,394 N/A z-5' Level 0012 Peninsula Wetlands:. 2 N/A 17,272 N/A 2-4 0013 Peninsula Wetlands 2 N/A ]9,011 N/A 0014 Canal Sediment 1 N/A 1,870 N/A 0015 Canal Sediment Within SU 1 N/A .1,170 N/A 9106-007 I November 2006 2-54 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area im2) .:Ratio SreSuvyAreaSurvey Area Survey Unit*
Survey Survey Unit MARSSIM Floor Total (Total Area: Figure Area FlooeNo.
Code Description Class.
Clss Are Area* Floor No CoeCode Description Code Code
- . *_.._.__. A rea) 9302 Northwest Protected Area L A 3 Land Area 3 N/A 6,410 N/A Grounds 0000 Southwest Protected Area Z2-z 9304 Grounds0001 Land Area 3 N/A ,0 N/A 0002 Land Area 1 N/A N/A South Central Protected Area 2 N 4 Grounds 0000 Land Area 2 N/A I 4,780 N/A Northeast Protected Area 0001 Containment 1 93Grounds Footprint/DWST IN/A,980 N/A 0002 Spent Fuel Bldg Area 1 N/A 1 1,806 N/A ZrL 0003 Terry Turbine/CST 1 N/A 1,481
- 1S N/A a-2 --
November 2006 2-55 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10, MARSSIM Classifications
___...__ Area (m2)
Ratio Survey Survey Area Survey Survey Uniit . MARSSIM Floor Total (Total Figure Area Unit Area:
Code Code Description Code- CodeDescription Class. Area Area Floor No.
.:. . .. .
- j *.* / Area)
North RCA from EDG BldgA -' A 9312 0004 B 1 N 18EastwardN/A Eai 0005 Tank Farm and Resin Facility 1 N/A 1,454 N/A 0006 PAB Footprint I N/A 11,749 N/A 0007 RRF Bldg/115kV East 1 I
N/
N/AW__ N/A Footprint 0008 115kV West Side GW . " N Treatment Facility 1,348 0009 East Trench North N/Aj N/A N/A 1 0 East Trench SouthIMWST A&B N/A.
November 2006 2-56 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area !(m')
Ratio Survey Survey Area Surveynit :Survey Unit MARSSIM Floor Total (TotalArea:Figure Code Code Description C Code Description Class. Area i.Area Floor No.
Area) 9313 Central Site Grounds 0000 Land Area . 2 N/A 5,850 N/A (j Bypass Road;econdary Parking lot 9504 (Add N. Portion of 9502) (Info 0000 Land Area 2 N/A 5,692 N/A 2-1
-- r _
Only) I -4 - F 4
-NortL Site Grounds (Non-Protected 9506 Area)*(Add EOF Parking Area from 0000 Land Area 3 N/A 1 =2,1 2 0 N/A 2-1 95 10) (Info Only) ,11 11 Ij 9508 Pond 0000 Land: Area and Pond Sediment 3 N/A 1,0,831 N/A 2-1 Northwest Site Grounds (Non-9512 Protected Area) (Remove Truck 0000 Land Area 3 N/A Z41. 81 N/A 2-1 Monitor and Roadway) (Info Only) . 3*, qy!
PrimP___arking "L(Add the S.
\JVe*~ 9514 Portion of 9502) Add Truck 0000 Land Area 3 N/A 954 Monitor and Roadway From 9512) 000Ln ra3NA 695 N/A 2-1 (Info Only) "".____ ' -
vot' PA41-1 /4 b r141 2,oO s l
<5 3 November 2006 2-57* Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area[(m )
Ratio Survey Suve Survey AreaS urvevy Survey Unit "MARSSIM Floor Total (Total Figure Area Unit Area:
Code Code Description Code
- o. Code Description
'C . . . .. Class. "d. Area
.e Area Floor Fl o o r No.
C o d
__ Area) 952 ( -.Sothwest Site StoragefArea 0001 Land Area, North Peninsula 2 N/A 19,870 N/A 2-2 2-2 (Add a Portion of 9518) Info Only. 0002 Land Area, North Peninsula 2 N/A :9,845 N/A 2-3 ELL-FF Ad a Portion of 9518) Ifo Only 0003 Land Area, North Peninsula 2 'N/A 18,106, N/A 0004 Land Area, North Pen insula. 1 NIA 1,983 N/A 2-3 0005 Land Area, North Peninsula. 1 N/A 11,887 N/A 2-3 9521 Southeast Pond 0000 Land Area and Pond Sediment 3 N/A 23,100 N/A November 2006 2-58 Rev. 4
Haddam Neck Plant License Tennination Plan Table 2-10.
MARSSIM Classifications Area (m2)
Ratio (Total Survey Survey Unit MARSSIM. Floor Total (Total Figure Area Survey Area SeSurvey Unit Ar...a..
ArdeaC d ecito uAreae Nr.
Code Code Description. Class.
Class Area.
. Area " Floor No.
Code Code Description
, ____ _ Area) 9522 Scuthw-;l Site St*i age Aa 0001 Land Area 2 N/A Lan A* N/A 24"""N')
ee- _o'-t _
0002 Land Area " N/A N/A 21,913 N/ 1,91 N/A r<-4 0003 Land Area. 150m East of Load 1 N/A N/A distribution Tower ". .",997 N 0004 Land Areaq:. "N/iA N/A 0005 East Side Land of Canal . N/A 1,947 N/A 0006 South RCA Land Area .N/AA 1,987 N/A 0007 South RCA Land.Area I N/A N/A
_________ _FI 9-/ A November 2006 2-59 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Arear (ml SuvySurvey ""- Ratio (Total Fgr Survey Survey Area Survey Unit MARSSIIM Floor Total a Figure Area Unit Class. Area Area Area:
Floor No.
Code Code Description Code Code Description
_Area) 3 N/A 106,000 N/A n2-,4 :2-7 9523 Southeast Wetland Area 0000 Land Area 9524 South Side Grounds (Non-Protected Area) 0000 Land Area .10,000 3 N/A N/A ý7 9525 Southeast Site Road 0000 Land Area: 3 N/A 128,000 N/A 9526 Northeast Mountain Side 0000 Land Area. 3 N/A 44,700. N/A 7
0001 Land Area 2 NA 6,536 N/A A-7 0002 Land Area 2 - N/A 6,069 N/A ;?-7 9527 East Mountain Side 0001 Land Area: 2 N/A 8,600 N/A o?-7
, .. ./A* A/ qof November 2006 2-60: Rev. 4
Haddam Neck Plant License Tennination Plan Table 2-10 MARSSIM Classifications Area. (m2) __
Ratio SSurvey urvey Area S eSurvey Unit. MARSSIIM Floor Total (Total Figure Unit Area:
Area Code Code Description Code Code Description Class. Area. Area Floor No.
Code "od Area) 0003 Land Area 2 N/A 8,200 N/A 0004 Land Area. 2 N/A 5,400 N/A 0005 Land Area 2 N/A 1N/A 0006 Land Area I N/A C§631 N/A 9528 Southeast Mountain Side 0000 Land Area,,, 3 N/A *75,488 N/A 0002 Land Area:, 2 N/A 9,752 N/A 2-4 0003 Land Area, 2 N/A 19,447 N/A November 2006 2-6.1 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications Area (m2)
Ratio Survey Survey Unit MARSSIM Floor T (Total Figure Unit . ' " Ta Area:
Area Survey Area Code Code Description Class. Area. Area Floor No.
Code Code Description
- _*______,Area) 0004 Land Area' 2 N/A 3,058 N/A Land Area'Bounded by and 9530 Central Peninsula Area 0001 Immediately Adjacent to the 2 N/A 8,000 N/A Road Western Half of Diked Area and 2 N/A 5,000 N/A 2-4
.Immediately Surrounding Sides -
0003 00 Eastern Half of Diked Area and Immediately Surrounding Sides 22 N/A N
5,000 50 N/A A 2-4 0004 Open Land Areas. 3 N/A 97,000 N/A 2-4 9531 South End of Peninsula 0000 Land Area, 3 1 N/A 118,000 N/A East Side Grounds (Non- N/A75,600 Non- N 9532 Protected Area) N/A N/A impacted N/A 375,600 N/A November 2006 2-62. Rev. 4
Haddam Neck Plant LicenseTermination Plan Table 2-10 MARSSIM Classifications
__Areal (m __)
SSurvey ure raSurvey "::: ai Ratio urvea Survey Area Su y Survey Unit MARSSIM Floor Total (Total Ar...a: Figure Area CoeDsrpinUnit CodeCode Description Code Code Description.. Class. Area Area Floor No.
._..
- Area) . .
9535 South East Landfill Area 0001 Land Area 1 N/A 1,900 N/A ,z-7 0002 Land Area 2 N/A 3,600 N/A ConstructionRange Piles Near Rifle 9536 0000 Land Area. 2 N/A .2,200 N/A r2-4 Pt -7 9537 Permitted Landfill Area 0000 Land Area 2 NIA 2,200 N/A J 9538 Material Storage Area 0000 'Land Area "N/A 2 N/A 9539 ISFSI Haul Road 0001 -14iSFSI Haul Road 2 N/A . 19,332 N/A 0002 S-vonth ISFSI Haul Road 2 N 7,236 N/A 2-4
'5 __ __ _ __ _
November 2006 2-63 Rev. 4
Haddam Neck Plant License Termination Plan Table 2-10 MARSSIM Classifications
_ _, - : A re a' 2) .
SuvySurvey .. R atio (Total:
Survey Survey Area Survey Unit MARSSIM Floor Total Figure reArea Unit Area:
Code Code Description Code Code Description Class. Area I Area Floor No.
. .Area) 9801 Subsurface soils in Radiologically Subsurface Soil A* N/A 1 N/A Controlled Area (excluding 9308) 0000 S *. "
Subsurface soils associated with surface soil survey area 9308 and 9802 subsurface soil areas within the 0000 Subsurface Soil B* N/A 118,292. N/A industrial area but outside the radiologically controlled area Subsurface soils associated with "
9803 parking lot, Warehouses I & 2, and 0000 'Subsurface Soil C* N/A 35,485 N/A 2 S te am G e n e ra tor M oc k u p B ld g "* "' - .'_"- - . .- .
Subsurface Žs associated with 0 S a S A* N2-9804tGro 0000 SubsurfaceS;ii: A* N/A 1 N/A 9804 South
( t' o I ast-te c- Grounds Ae-e* "- -
- _ ,_ " _
Subsurface soW4 ssociated with 0 9805 peninsula (excluding area 9531) 0000 Subsurface Soil. C* N/A 104,207 N/A Subsurface soils associated with 9806 surface soil portions of survey area 0000 Subsurface Soil. A* N/A 4250 N/A29 9535 (South East Landfill) "_ _...._ _._._
9807 Subsurface Soils associated with 0000 subsurface Soil B N 193 /
9 5 2 0 -0 0 0 4 0000 S ub u rfa c e_ oi . -. B* -1. N /A 98 3 N /A ( 2 -9
- MARISSM does not cover media such as subsurface soil, which is considered beyond its scope. LTP Section 5.7!3.2.1 discusses the criteria applied during the classification of subsurface soils.
November 2006 2-64 Rev. 4
99514-0000 9512-000 ConnecticutRiver CONNECTICUT YANKEEATOMICPOWER COMPANY A "WIONIMI APRL2002 LEGEND I Plant UE T$o -
PaCY UPDATE SUR VEY UNIT BOUNDARIES cCARtffY0 JEODTE Surface Areas
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Haddam Neck Plant License Termination Plan Depending on the values of the applicable DCGLs, an alternative method of using material specific backgrounds may be used during final status surveys. This alternative method will involve the determination of the ambient area background in the survey unit and will only be applicable to beta-gamma detecting instruments. This determination will be made prior to performing a final status surve* at a location within a survey area that is of sufficient distance (or attenuation) from the surfaces to eliminate beta particles originating from the surface from reaching the detector. At such a location, the ambient background radiation will be due only to ambient gamma radiation and will be a
-back-ir ffiiind
&i- p-rie-t o s -aace-lisefrac-senents-iTs The-h average background -
determined at this location can be used as a conservative estimate since it is expected to be less than the material specific background for the material in the room because it does not fully account for the naturally occurring radioactivity in the materials. Using this lower ambient background will result in conservative calculated residual radioactivity levels. If the average background reading exceeds a predetermined value, the survey would be terminated and an investigation performed to determine and eliminate the reason for the elevated reading. Each of the survey unit readings would subtract this average background value and the Sign Test applied.
Whether or not they are radionuclideS pecific, all background measurements should account for both spatial variability over the area being assessed and the precision of the instrument or method being used to make the measurements. Thus, the same materials or areas may require more than one background assessment to provide the requisite background information for the various survey instruments or methods expected to be used for final status surveys. The results, may cause thonain in the-areaof the ao araa c aor y adjacntareatis determining the mean anId its associ tconsideration 5.4.6 Area Preparation: Isolation and Control bb "
Before final status survey activities an begin in an,, ea, a transition must occur where planned decommissioning activitie e completedand the area is subsequently assessed to scope the required isolation and control measures. This includes establishing if the area is ready for final survey activities and identifying any work practice issues that must be addressed in survey planning and design. Determination of readiness for final status survey will be based on characterization and/or remediation surveys indicating that the residual radioactive material is likely to comply with the final status survey criteria.
During and following this assessment, the remediation of an area for the purposes of.
removal of residual radioactivity, a Remedial Action Survey (RAS) will be performed.
This RAS will include scanning and sampling of the areas, as necessary, using appropriate instrumentation to ensure the intended remediation has been accomplished.
If no further remediation is required, a turnover survey may be performed as necessary.
Data from the RAS may be used for the turnover survey and as input to the design and DQOs for the surface and subsurface FSS.
5-12 Rev. 4 November 2006 November 5-12 Rev. 4
Haddamn Neck Plant *LicenseTermination Plan It is noted, however, that characterization efforts for groundwater contamination are still ongoing and the survey areas to which the HExistingGW iterm are applied may change. Those changes will be communicated to the NRC. This change may be caused by changes in the location of the plume, detection ,of groundwater contamination at locations outside the plume or changes to the capture zone or detection of groundwater contamination at locations outside the zone. The Phase 2 Hydrogeologic Work Plan, as described in Section 2.3.1.6,.will provide additional characterization.of groundwater that will be used to better define the groundwater contamination plume.
Prior to the.request to release of any portion of the site from the license, CYAPCO will prepare and make available for inspection a capture zone :analysis provided to the NRC in January 2005, based. on data collected. as part of the Phase 2 Hydrogeological Work Plan, to better. define the capture zone distance, Reference 5-13. The "capture zone", is the area surrounding a hypothetical well to be used by the resident farmer, from which existing groundwater contamination could be drawn into the resident farmer's well. The analysis used to determine this area used the hydrogeological conditions and parameters assumed in the Resident fanner Scenario as described in Chapter 6 of the LTP.
Table 5-3 SureyUntsAffected by Groundwater Contaminato Existing Future Groundwater Groundwater Zone of Influence Concrete 9302 9302 S9304-1&2. 93044!&2 9306 9306 9312-1 Thru 10 9312-1 Thru 10 9313 9313 9522-5, 6 & 7 9522-5, 6 & 7 9801 9801 9802 9802 9106-1, 2, 3,4 & 14 N/A 9512 N/A 9514 N/A 9520-1, 2, 3, 4 & 5 N/A 9521 N/A 9522-1, 2, 3 & 4 N/A 9527-1, 2, 3, 4, 5 & 6 N/A 9528-0, 2 & 3 N/A 9530-1, 2, 3 & 4 N/A I
9803 N/A
.1~~
I.- "/AA qS*3 T-6 vOd 9804 N/A 9805 N/A 9807 N/A November 2006 5-20 Rev. 4
Haddam Neck Plant License Termination Plan The compliance formulation for these resident fanner exposure scenarios is re-written as:
(Equation 5-5)
U) l DCGLop-oi 1"-.(-, 1 +÷PSi
+/- DCGLoP-.istingGCTR+H + FtrG FutureGW LDCGLBase-Soil DCGL BasexistjfgGW 25 For simplicity Equation 5-5 may be re-written as:
S1 _ (i)[fsol + f+/- gW + fFururG] (Equation 5-6)
Where, for a given radionuclide i, f'so il is the fraction of the total dose from soil.
f.ExistingGW iS the fraction to the total dose from existing contamination in groundwater f FutureGWiS the fraction of the DCGL 25 mrem/yr dose that is calculated by the Basement Fill Model. G b A5E ,
The use of this equation requires that only one variable be unknown. Therefore, values for Future Groundwater dose and fi ExtingGwwill need to be selected in order to calculate fsoil As the building surface operational DCGL are independent of soil and groundwater dose contribution, they will be set based on an ALARA evaluation and/or an administrative dose level at or below 25 mrem/yr.
The following example is provided to illustrate the use of the operational DCGLs for land areas that have the potential for existing and future groundwater dose, with the following assumptions:
Sf[soai=0.3
- fExzWtngGW = 0.2
- Therefore, Future Groundwater Dose (fraction of 25 mrerm/yr) = 0.5 The above determination will be made prior to the performance of any final status surveys of soils or building surveys in areas where existing groundwater contamination will impact the potential dose. This determination will be provided in the FSS Report or a technical support document and will be applied to the affected survey areas.
The following table provides an example of the building surface operational DCGL for Cs- 137 using the fractional values from above.
November 2006 5-21 Rev. 4
Haddam Neck Plant License Termination Plan q* hl* 1[_'7 JelI Release vimits for Buried Piping, dpm/100Icmn2 -__""__
2" 2 1/2" 3" 4" 8" 10" 12" 14" 16" 18" 20'! 24" 26" Radionuclide___
H-3 1.30E+03 2.61E+03 3.26E+03 3,91E+03 5.21E+03 1.04E+04 1.30E+04 1,56E+04 1.82E+04l 2.08E+04 2.34E+04 2.61E+04 3.13E+04 8.47E+03 C- 14 1.94,+04 3.89E-,04 4.86E+04 5.83E+04 7.77E+04 1.55E+05 1.94E+05 2.33E+05 2.72E+05 3.1 IE+05 3.50E+05 3.892+/-+05 4.66E+05 1.26E+05 Mn-54 1.331+04 2.66E+04 3.32E+04 3.98E+04 5.31E+04 1.06E+05 1.33E+05 1.59E+05 1,86E+05 2.12E+05 2.39E405 2.66E+05 3.19E+05 8.63E+04 Fe-55 1.54E+04 3.09E+04 3.86E+04 4,63E+04 6.17E+04 1.23E+05 1.54E+05 1.85E+05 2.16E1+05 2.47E+05 2.78*+05 3.09E+05 3.70E+05 ;OOE+05 Co-60 8.03E+04 1.61 E+05 2.01E+05 2.41 E+05 3.21E+05 6.42E+05 8.031305 9.63E+05 1.12E+06 I.28E+06 1.44E+06 1.61E+06 1.93E+06 5.22E+05 Ni-63 3.80E+04 7.60E+04 9.50E+04 1,141+05 1.522+05 3.04E+05 3.80E+05 4.56E+05 5.32E+05 6.081+05 6.84E+05 7.60E+05 9.121+05 2.47E+05 Sr-90 4.68E+01 9.352+01 1.17E+02 1,401+02 1.87E+02 3.74E+02 4.68E+02 5.61E+02 6.55E+02 7.48E+02 842E+02 9.35E+02 1.J2t+03 3.04F+02 Nb-94 3.43E+04 6.85E+04 8,56E+04 1,03E+05 1.37E+05 2.74E+05 3.43E+05 4.11E+05 4.80E+05 5A48E+05 6.17E+05 6.85E+05 8.22E+05 2.23E+05 Tc-99 6.10E+03 1.22E404 1,53E+04 1.83E+04 2.44E+04 4.88E+04 6.10E+04 7.32E-k14 8.5413+04 9.76E+04 .IOE+05 1:22E+05 1.46E+05u 3.972+04 Ag-108ni 3.43E+05 6.85E+05 8.56E+05 1.03E+06 1.37E+06 2.74E+06 3.43E+06 4.1 IE+06 4.80E-f.06 5.48E+06 6.17E2+06 6.85E+06 8.222+06 2.23E+06 Cs-134 2.09E+04 4.18E+04 5.22E+04 6.26E+04 8.35E+04 1.67E+05 2.09E+05 2.5 IE+05" 2.92E+05 .3.34E+05 3.76E+05 4.18E1+05 5.01IE+05 1,36E+05 Cs-137 2.42E+04 4.83E+04 6.042+04 7.25E+04 9.66E+04 1.93E+05 2.42E+05 2.90E+05 3.38E+05 3.86E+05 4.35E+05 4.83E+05 5.802+05 1.57E+05 Eu-152 6.70E+04 1.342+05 1.68E+05 2.01E+05 2.68E+05 5.36E+05 6.70E+05 8.04E+05 9.38E+05 1.07E+06 1.21E+06 I.342E+06 1.61E+06- 4 36E+05 Eu-15 4 4.68E+04 9.35E+04 1.171+05 1.40E+05 1.87E+05 3.74E+05 4.68E+05 5.612+05 6.552+05 7.48E+05 8.42E+05 9.35 2.+05 1.121+06 3,042+05 Eu- 155 3.00E+05 6.00E+05 7.50E+05 9.00E+05 1.201+06 2.40E+06 3.OOE+06 3.60E2-6 4.20E+06 4.80E+06 5.40E+06 6.OOE+06 7.20E+06 1.95E+06 Pu-238 1.88E+02 3.752+02 4.-69E+02 5,632+02 7.502+02 1.50E+03 1.88E+03 2.258+03 2.63E+03 3.00E+03 3.38E+03 3.75E+03 4.50E+03 1.22E+03 Pu-239 1.7 1E+02 3.41 E+02 4.26E+02 5.12E+02 6.82E+02 1.36E+03 1.71E+03 2.05E+03 2.39E+03 2.73E+03 3.07E+03 3.41E+03 4.09E+03 1.11 E+03 Nu-241 2.852+03 5.70E+03 7,13E+03 8.55E+03 1.141+04 2.281+04 2.852+04 3.42E2+04. 3.99*+04 4.56E+04 5.13E+04 5.70E+04 6.84E2+04 1.85E+04 Am-241 8.33E+01 1.67E+02 2.081+02 2.50E+02 3.33E+02 6.66E+02 8.33E+02 9.99E+02*.1. 17E+03 1.33E+03 1.50E+03 1.67E+03 2.00,-3 5.,41E+02 Cm-23 I.15 E+02 2.3 1E+02 2.89E42 3,46E+02 4.1+29.226+02 E3 5+0 42 4.61+02 920 1.152+03 1.38E÷03 1.61E+03 1.84E+03 2,07E+03 2.3 1E+03 2.77E+03 7.49E+02 5-29 Rev. 4 November 2006 5-29 Rev. 4
Haddam Neck Plant License Termination Plan Part of the planning for the final status survey of a particular survey unit will include an evaluation of the surfaces to be monitored. For conventional instrumentation, surface anomalies will be identified as part of this process and will be taken into account when selecting efficiencies to convert instrument readings to activity and in the calculation of the corresponding MDCs. Conservative values will be chosen based upon surface conditions. If the condition of the surface in the area changes in a more conservative direction (e.g. shorter detector to surface distance), the effect on the MDC will be assessed but may not be re-derived. If the condition of the surface changes in a non-conservative direction (e.g. different construction material which a.i-a-s ri*,triitur radioactivity) the-lIDC willt-be-assessed- andree-derived. . -
Expm-nsion joints, stress cracks, floor/wall interfaces, and penetrations into floors and walls for piping, conduit, anchor bolts, etc., are potential sites for accumulation of contamination and pathways for migration into sub-floor soil and hollow wall spaces.' Roof surfaces and drainage points are also important survey locations. In some cases, it may be necessary to core, drill, or use other methods as necessary to gain access to areas for sampling.
5.7.3.1.1 Activity Beneath Surfaces basements.____
b/¢ oasements wil e*aut wll be evaluat Exteriior surfaces of below-grade, Tderijstocal site ass sriti
.s other pertinent records to determine the potential for sub-surface contamination on these surfaces of be'owe avalabe he exterior t *ealute xteiorsurace
-available toevaluate the surfaces ~ the use of sufacs o b~owgradebasemenlts. One method core.bores through foundation or walls and the taking of soil samples at locations having ahigh potential for the accumulation and nlwaion of radioactive contamination to sub-surface soils. These biased locations for soil and concrete assessment could include stress cracks, floor and wall interfaces, penetrations through walls and floors for pipin*,
run-off from exterior walls, and leaks or spills in adjacent outside areas, etc. If the soil is found to be free of residual radioactivity at the biased locations, it will be assumed that the exterior surface of th e foundation is also free of residual activity. Otherwise, additional sampling may be necessary to determine the extent of decontamination and remediation efforts. Another method available for evaluating the exterior surfaces of below-grade foundations is gamma well logging. Soil in biased locations next to the extrio o th buldng ma eeauated using this technique. This technique can provide for rapid isotopic analysis of soils without' sampling.
r me urem s can sti 1 e pe ormed with the required sensitivity relative to the
- j.applicable DCGLs.
S5.7.3.1.2 Below-Grade Building Foundations 5.7.3.1.2.1 Basement Basement concrete that is to remain will be characterized to determine the extent of any volumetric contamination of the concrete in accordance with Table 5-10. The results will be used in the calculation of the Basement Fill Model.
November 2006 5-61 Rev. 4
Haddam Neck Plant License Termination Plan The results of this sampling or assessment will then be used as input to the calculation of future groundwater dose using the basement fill model as discussed in Chapter 6.
The results of sampling and/or assessment of the external surfaces will be used in the design and DQOs of the subsurface FSS to be performed in the area. Following any re uired remediation approximately 4 feet of backfill soil would be placed over the footingslo restore the area to Theýneed-for-a firalstatus-survey-of-the-areas-with-below-ggrade-striuctures-w-illbedetermined-on a __
graded approach.
For footings and other structures to remain that have a very low or no potential for contamination such as:
- Buildings outside the RCA;- and
- Buildings shown by characterization sampling to be free of residual radioactivity; the final status survey will consist of a survey and subsurface FSS of the area including the subsurface structures.
5.7.3.1.3 Sewer Systems, Plumbing Residual radioactivity -in sanitary piping or floor drains will be evaluated in the same. manner as for non-structural plant systems or components, discussed in Sections 5.4.7.5 and 5.6. Assessment of
..residual activity levels in piping or floor drains will be via sampling.of sediments, fixed measurements, scanning, or a combination of these methods, as appropriate.
All non-RCA sanitary systems at the Haddam Neck Plant drain to on-site leach fields. These systems are independent of other plant systems and all surface water or storm drains. If any residual radioactivity is suspected in portions of the sanitary plumbing systems, evaluations for both the leach fields and the associated system piping may be required. Radiological assessments of piping will be made as described in Section 5.6 of this plan, i.e., by full length surveys of interior surfaces. Evaluations required for any affected leach fields will be made as described in Section 5.7.3.2.2 of this plan, for sub-surface activity. All operable RCA-located systems currently drain to the aerated drains system and are part of the normal plant effluent. Thus, there are no leach fields associated with these systems. During the plant lifetime, toilet facilities, showers and sinks, contained within the RCA, drained to the plant sanitary system and associated leach field. Any piping associated with the systems, which is proposed to remain following decommissioning will be evaluated as described below.
November 2006 5-63 Rev. 4
Haddam Neck Plant License Termination Plan
- Internal dose from ingestion of
- Plant foods grown in media containing residual radioactivity and irrigated with water containing residual radioactivity,
- Meat and milk from livestock fed with fodder grown in soil containing residual radioactivity and water containing residual radioactivity,
- Drinking water (containing residual radioactivity) from a~well,
- Fish from a pond containing residual radioactivity, and
_ Media-containing-esidual-radioactivit-y.-__ _____
6.3.3 Building Occupancy Scenario Scenario Defimition-: :
The building occupancy scenario, based upon NUREG/CR-5512, Volume 1, was selected to estimate human radiation exposure resulting from residual radioactivity in concrete from standing buildings and building foundations/basementsthat could reasonable be occupied and todetermine corresponding DCGLs. CYAPCO will not leave any basements in place that can be reasonably occupied. These DCGLs are also used to bound residual contaminationlevels on metal surfaces such asfe con ainmentl d LE embedded piping to be subsequently used in the calculation of, ggounwater" dose due to contamination on these metal surfaces.
Critical Group:
Given the fact that the buildings associated with the HNP site are commercial, the average member of the critical group is an adult engaging in light industrial work within the buildings following decommissioning of the site. He/she occupies a commercial facility in a normal manner without deliberately disturbing sources of residual radioactivity. The dose from residual radioactivity in the concrete from the standing building is evaluated for the average member of the critical group as required by 10 CFR Part 20, Subpart E, and described in NUREG -1727, Appendix C.
Exposure Pathways:
The potential exposure pathways, described in NIJREG/CR-5512, Volume 1, are depicted on Figure 6-4 and listed below:
- Direct exposure to external radiation from
- Source
- Material deposited on the floor
- Submersion in airborne dust
- Internal dose from inhalation of airborne radionuclides
- Internal dose from inadvertent ingestion of radionuclides from the source November 2006 6-7 Rev. 4
Haddam Neck Plant License Termination Plan Table 6-2 Base Case DCGLs for Groundwater Radionuclide Groundwater DCGL (pCi/I)
H-3 6.52E+05 C-14 9.01E+03 Mn-54 2.42E+04 Fe-55 6.54E+04 Co-60 1.14E+03 Ni-63 3.15E+04 Sr-90 2.51E+02 Nb-94 6.75E+03 Tc-99 .2.64E,04 Ag-108m 4.24E+03 C-- 134 3 .A Cs-137 4.31E+02 Eu-152 7.33E+03 Eu-154 5.05E+03 EU- 155 3.25E+04 Pu-238 1.51E+01 Pu-239 .. 36E+01 Pu-241.: 4.60E+02 Am-241 1.32E+01 "
Cm-243 1.94E+01 6.8 DCGLs for Concrete A few of the building basements and footings at HNP will remain in place and be surveyed orassessed for residual -radioactivity. Presently CYAPCO's plan is to backfill these partial structures with clean material from off-site or on-site material shown to meet the soil DCGLs once the final status survey or assessment of the -structure has been completed. The site dose contribution from these basements will be calculated using the Basement Fill Model as discussed in Section 6.8.2. -Ftorbuildings to-remafian after-eleta.e f-om *,lice~n. 3,th-B G 4..* pbr-r& D.CCLwl l-T c iedt Pe-uIrt . VAP rL- 6,e- '-c 6.8.1 DCGLs for Concrete: Buildings Standing , t,- F,,-e rP 6.8.1.1. Dose Model I* 1-e-Le- aJrw
/P c- ,r- " -, ez e Presently the only building to remain on-site is the Emergency Operations Facility (EOF). The plan is to free release this structure in accordance with current regulations.
The structure is located outside the industrial area at the extreme north boundary of the owner controlled area.
6-18 Rev.4 November 20062006 6-18 Rev. 4
Haddam Neck Plant License Termination Plan Using the parameter values above with equations 6-4 and 6-6, the calculated groundwater concentrations and dose are conservative as a result of the following simplifying assumptions.
- The concrete surfaces are assumed to be represented by a semi-infinite geometry.
- No credit is -taken for the barrier to diffusion that the incore instrument area containment liner provides.
- The Brookhaven Study assumes that 2.5 feet of grout (flowable fill) will be placed above the activated concret region 6fith- ICbre-Sel-.mp. -The-depth-of-grout-placed---.-------......
above. the activated region will actually be 5 feet, thereby. providing additional:
resistance to.transport.
The analysis provided by Reference 6-19 is specifically for the containment and spent fuel pool basements taken together. Other adjacent subsurface structures such as the cable vault portion of the containment and other footings will be inventoried in a similar
.manner and added to the containment dilution volume footings assessed after completion of the spent fuel pool Basement Fill*Model Calculation will be included with the discharge tunnel inventory. This approach will also be used for other basements that remain. (i.e. "B" Switchgear and the discharge -tunnels) although the released radioactivity from these additional basements will be assumed to migrate and. be included with the discharge tunnel inventories.
6.8.2.3 Future Groundwater Dose Calculation for Surface Contamination on Embedded Piping The last source to be evaluated in determining the future groundwater dose from buried structures and components is that resulting for the surface contamination contained on embedded piping to remain after termination of the license.
Embedded piping is that which is present in the containment or spent fuel pool basement and will not be removed or grouted. This source will be included in the calculation of the containment interior groundwater concentration. se7 e ! conta'_ment a inr trface activity surveys will be performed in accordance with Section 5.4.7. using building occupancy DCGLs determined by an ALARA evaluation or administrative limit.
Using the radionuclide mix from these and other characterization surveys, each pipe will be assumed to be contaminated to levels equivalent to a total contamination level corresponding to building occupancy DCGL being used. Using this inventory, a CFR value of 1.0 will be used along with the total surface area, and, equations 6-4 and 6-6 will be used to calculate the future groundwater dose and concentrations. These values will be added to their respective values for the concrete case discussed in 6.8.2.2. This is C(,
conservative approach since it assumes:
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Haddam Neck Plant License Termination Plan
- 1. that the total inventory of radioactivity for each radionuclide is released to the groundwater/backfill soil system assumed in the containment basement in the first year after release of this area from the NRC license, and
- 2. that all surfaces are contaminated to a level equivalent to the building occupancy DCGL.
6.8.2.4 Summary of All Future Groundwater Dose Calculations .
Sections 6.8.2.2066.8.2.3 show the method to be used to determine the future,' A-A 5 7-$-C
-groundwater-dosesduet0othe-individ~ualsQurces, buried concrete, liner and embedded piping. The individual doses will next be summed to determine the total future groundwater dose from allsources. This Calculated dose will be used to supply the "future groundwater" dose component of the compliance equation (5-1). In the case of the containment basement, the future groundwater dose will be calculated as given in the methodology above. THis calculation will be perfred concurrent with thle survey 0f the containment and be available for NRC review prior to the backfilling of the containment basement.
This approach will also be used for other basements that remain (i.e. "B" Switchgear and the discharge tunnels) although, the released radioactivity from these additional basements will be assumed to.migrate and be includedwithfthedischarge tunnel inventories.
6.9 Operational DCGLs Since additional scenarios, beyond those described above, may be created by combining pathways from different scenarios (e.g., resident farmer with the future groundwater dose calculated using the Basement Fill Model), a method to assess doses from these combined pathways is necessary. Additionally, any initial residual radioactivity in
,groundwater that exists will also contribute to total dose. For example, a resident farmer may locate his residence and raise crops on soil containing residual radioactivity and use groundwater that is in contact with a buried basement, which may also contain residual radioactivity. Soil and groundwater DCGLs for these combined scenarios along with the future groundwater dose calculated using the Basement Fill Model will be determined on an operational basis, using the base case DCGLs for soil and groundwater and future groundwater dose, calculated in Sections 6.6, 6.7, and 6.8. Section 5.4.7.1 describes, in detail, the methodology to account for all of these contributions.
November 2006 6-26 Rev. 4
Haddam Neck Plant License Termination Plan This cost estimate was prepared by Northeast Utilities Service Company (NUSCo) using the TLG Services, Inc., estimating model in accordance with 10 CFR 50.82(a)(8)(iii). The assumed method of decommissioning anticipated a prompt decommissioning technique commonly referred to as DECON. After other revisions to the decommissioning cost estimate as described below, on August 15, 2006. the Company filed a rate settlement with FERC which is pending FERC approval.
7 Decommissioning Cost Estimate 7.2.1 Cost Estimate Previously Docketed in Accordance with:10 CFR 50W82 and 10 CFR 50.75 Post Shutdown.
A letter from CYAPCO to the USNRC dated August 22, 1997 (Reference 7-3) was docketed detailing the PSDAR. This submittal contained, a site-specific decommissioning cost estimate. In accordance with 10 FR 50.82(a)(8)(iii), CYAPCO submitted the site-specific decommissioning cost estimate to the USNRC in a letter *dated August 25, 1998 (Reference 7-4). The estimate included with the PSDAR had been filed with the FERC prior to docketing. This estimate was the basis for which CYAPCO.
collected its rates and its anticipated decommissioning expenses..This cost estimate was prepared by.NUSCo in 1996 using the TLG model for estimating decommissioning costs.
It was prepared in sufficient detail to identify an activity by activity work breakdown complete with costs for radioactive waste, utility labor, contractor labor, energy, materials and equipment.
In August of 1998, the presiding Administrative Law Judge (ALJ) in the FERC case issued an opinion to the FERC Commissioners that the estimate was "unreliable for rate-making" and recommendations were made identifying appropriate remedies based on the factual data submitted from CYAPCO and intervening parties. CYAPCO prepared a revised cost estimate and engaged in settlement discussion with the certain intervening parties to the rate case. A settlement agreement incorporating the revised decommissioning funding plan was reached in April 2000 and submitted to the FERC for their review and approval. The settlement was approved by the FERC in April 2000.
7.2.2 Summary of the Site Specific Decommissioning Cost Estimate The previous FERC approved decommissioning cost estimate was based on the April 2000 Offer of Settlement between CYAPCO and the Connecticut Department of Public Utility Control and the Connecticut Department of Consumer Counsel (Reference 7-5).
A copy of the FERC-approved Settlement Offer is provided in Appendix C. This FERC-approved decommissioning cost estimate completely replaced and superseded the 1996 cost estimate prepared by Northeast Utilities Service Company using the TLG Services estimating model November 2006 7-2 Rev. 4