IR 05000309/2004001
| ML042310605 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 08/18/2004 |
| From: | Pangburn G Division of Nuclear Materials Safety I |
| To: | Meisner M Maine Yankee Atomic Power Co |
| References | |
| IR-04-001 | |
| Download: ML042310605 (18) | |
Text
ust 18, 2004
SUBJECT:
INTEGRATED INSPECTION NO. 05000309/2004001
Dear Mr. Meisner:
On July 29, 2004, we completed an integrated inspection at your Maine Yankee reactor facility of activities authorized by the above listed NRC license. We discussed our findings with Mr.
Thomas Williamson, Mr. James Connell, and others via a telephone conference on August 11, 2004. The enclosed report presents the results of this inspection.
During this approximately six-month inspection period, we inspected your operations and maintenance, security and safeguards, and plant support programs through selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors. We consider the programs to be implemented appropriately.
Our report documents apparent violations that are being considered for enforcement action in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. Two apparent violations, which were identified by your staff and reported to the NRC, involve (1) the failure to perform certain performance checks for portable survey meters in accordance with procedural requirements and (2)
inaccurate records concerning such checks. The third apparent violation, which was identified by NRC in the review of your Final Status Survey Release Records, involves the use of 10 CFR 50.59 to increase the DCGLEMC without NRC approval pursuant to your license and License Termination Plan. We are continuing to evaluate these apparent violations and will inform you of any enforcement action by separate correspondence at a later date. You should note that the characterization of the apparent violations described in the enclosed inspection report may change as a result of further NRC review.
No response to this letter and report is required at this time. In accordance with Section 2.390 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations (CFR), a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Michael Meisner 2 We appreciate your cooperation with us during this inspection.
Sincerely,
/RA/
George Pangburn, Director Division of Nuclear Materials Safety
Enclosure:
Inspection Report No. 05000309/2004001
REGION I==
INSPECTION REPORT Inspection No. 05000309/2004001 Docket Nos. 05000309 & 07200030 License No. DPR-36 Licensee: Maine Yankee Atomic Power Company Location: 321 Old Ferry Road Wiscasset, ME 04578-4922 Inspection Dates: January 12, 2004 - July 29, 2004 Inspectors: Mark C. Roberts, Senior Health Physicist Decommissioning Branch Division of Nuclear Materials Safety (DNMS), Region I Randolph C. Ragland, Jr., CHP, Health Physicist Decommissioning Branch, DNMS, Region I John Buckley, Maine Yankee Project Manager Division of Waste Management and Environmental Protection Office of Nuclear Materials Safety and Safeguards (NMSS)
Bruce Watson, Health Physicist Division of Waste Management and Environmental Protection NMSS Approved By: Marie T. Miller, Acting Chief Decommissioning Branch, DNMS, Region I Enclosure
EXECUTIVE SUMMARY Maine Yankee Atomic Power Company NRC Inspection Report No. 05000309/2004001 This integrated inspection included aspects of licensee operations and maintenance, engineering, security and safeguards, and plant support programs. The report covers approximately a six-month period of announced inspections by two regional inspectors, two NMSS inspectors, and three NRC contractors from the Oak Ridge Institute for Science and Educations (ORISE) Environmental Survey and Site Assessment Program (ESSAP). The results of measurements by the ORISE team will be reported in a subsequent inspection report.
Operations & Maintenance The licensee used acceptable engineering practices and pre-job planning to incorporate safety and As Low As Is Reasonably Achievable (ALARA) practices in removing and demolishing major components and structures. The plant vent and neutron shield tank were demolished safely and collective personnel dose was less than the established goals. Spent fuel racks were removed and appropriately prepared for waste transport. No findings of significance were identified.
Maine Yankee staff implemented essential physical and procedural changes and provided training to effect the transition of its operations and security staff activities from its decommissioning site to full-scale operations at the Independent Spent Fuel Storage Installation (ISFSI). NRC and Maine Yankee staffs executed the exchange of correspondence to appropriately terminate the May 23, 2002, Order for Interim Safeguards and Security Compensatory Measures for Maine Yankee Atomic Power Company (MYAPC). No findings of significance were identified.
Plant Support Maine Yankee assembled a water treatment system for effectively filtering and processing contaminated water from the Spent Fuel Pool (SFP). Processed water is sampled and then discharged through an existing radiation monitor and discharge pathway. Confirmatory samples of processed water will be analyzed by ORISE and reported in a subsequent inspection report. No findings of significance were identified.
Review of Condition Reports (CRs) related to radiation protection (RP) department issues found corrective actions to be completed within procedural time requirements and thoroughly addressed the identified issues. Two apparent NRC violations were self-identified by the CR process regarding the apparent failure to follow procedural requirements for the response checking of radiation protection (RP) instrumentation and inaccurate records were apparently created regarding these checks. NRC has not completed its evaluation of these apparent violations and will inform you of any enforcement action separately.
The inspectors reviewed selected Final Status Survey (FSS) records including instrument calibration and technician training records and documents relating to the licensees March 15, 2004, submission of a license amendment request for the release of non-ISFSI lands from the license. One inspector follow-up item was opened to review training issues identified in the ii Enclosure
FSS Program. One apparent violation was identified by the staff regarding the use of 10 CFR 50.59 to increase the DCGLEMC without NRC approval in accordance with the license and LTP.
NRC has not completed its evaluation of this apparent violation and will inform you of any enforcement action separately.
iii Enclosure
REPORT DETAILS Summary of Facility Activities The plant was maintained in a permanently shutdown condition during this inspection period.
On February 27, 2004, Maine Yankee completed the transfer of spent fuel from their spent fuel pool (SFP) into dry cask storage at their Independent Spent Fuel Storage Installation (ISFSI).
Remediation activities, including surface scabbling and debris removal, continued in the Fuel Building and Primary Auxiliary Building, and demolition activities continued in the interior of the Containment Building. Soil excavation activities commenced in the area adjacent to the former Spray Building.
I. Operations & Maintenance O1 Conduct of Operations & Maintenance O1.1 Major Demolition Activities a. Scope (Inspection Procedures (IP) 71801, 83750)
The inspector reviewed the decommissioning activities related to the demolition and removal of major structures and components including the plant vent stack, the neutron shield tank, and spent fuel storage racks. Information was gathered through observation of work in progress, tours of the facility, a review of documents and radiological exposure records, and interviews with cognizant personnel.
b. Observations and Findings Plant Vent Stack Demolition The inspector reviewed the work order, engineering calculation, and the 10 CFR 50.59 evaluation prepared for demolishing the 173 feet tall, 60,000 pound plant vent stack.
The intent of this evolution was to safely demolish the plant vent stack without impacting the SFP. The licensees engineering evaluation and work order addressed issues involving thermal-cutting the vent supports and the base of the stack, fall protection during cutting operations, evacuation and exclusion of workers for final demolition, and engineering the appropriate direction of fall for the stack. Maine Yankee staff safely completed the stack demolition, cut the stack into sections, and disposed of the pieces as radioactive waste.
Neutron Shield Tank Demolition The final dose-significant phase of interior containment demolition was the cutting and removal of the neutron shield tank. The neutron shield tank surrounded the lower portion of the reactor vessel. The 1.5-inch to 2-inch tank walls became highly radioactive as a result of long-term neutron irradiation during the life of the plant.
Contact exposure rates ranged from 60-1000 milliRoentgens (mR)/hour and exposure rates inside the tank ranged from 100-700 mR/hour.
Enclosure
Tank walls were cut into pieces ranging from approximately 11,000 to 20,000 pounds using an oxygen-acetylene torch. The cut pieces were removed to a lower exposure-rate area for further segmentation as needed and wrapped in plastic for contamination control. The segments were then placed in shielded rail cars for transportation to and disposal at the Envirocare of Utah facility. A tent made of non-flammable fabric was erected over the cutting area and a HEPA filtration system was used to capture fumes and particulates from the cutting operation. In order to reduce doses to the cutting crew, Maine Yankee built a steel plate shielding box for the interior tank cuts so that the cutting device could be operated from a shielded position. Steel plates were also hung behind the cutting crew to further reduction of exposure rates. Health physics technicians and workers were observed to be following good As Low As is Reasonably Achievable (ALARA) practices by remaining in low exposure rate areas when possible and pre-staging equipment for efficient use of time in higher exposure rate areas.
Loading of cut pieces into the shielded railcars was conducted quickly with minimal time spent in the vicinity of the cut pieces of the tank. The overall tank demolition project was completed well within the original personnel dose goal.
Removal of Spent Fuel Pool Storage Racks Following removal of all spent fuel elements from the SFP, Maine Yankee commenced draining and decontaminating the pool and decontaminating and removing the spent fuel racks. Each cell of each of the racks was surveyed underwater to identify elevated contamination levels on the racks or the pool bottom. Measurements indicated elevated contamination levels in a few locations, but were not indicative of loose spent fuel pellets. Maine Yankee had a contingency plan, if measurements indicated the possibility of spent fuel pellets or pieces.
An in-pool vacuum and filtration system was used to collect readily removable contamination and underwater pressure-washing was used to further reduce contamination on racks. Racks lifted from the pool were re-surveyed, and if necessary, additional decontamination was performed. The racks were then wrapped in plastic film and placed in railcars for shipment and eventual disposal at the Envirocare of Utah facility.
c. Conclusion The licensee used acceptable engineering practices and pre-job planning to incorporate safety and ALARA practices in removing and demolishing major components and structures. The plant vent and neutron shield tank were demolished safely and collective personnel dose was less than the established goals. Spent fuel racks were removed and appropriately prepared for waste transport. No findings of significance were identified.
Enclosure
O1.2 Security and Operations Transition to the ISFSI a. Scope (IPs 36801, 60855, 81700)
The inspector reviewed the licensees transition plan for the Security and Operations staffs for the cessation of operations at the decommissioning site and the transfer of control functions at the ISFSI following completion of all fuel loading into sealed storage canisters and transfer to the ISFSI. Information was collected through interviews with the ISFSI Operations Manager, the Security Manager, and other cognizant personnel, tours of the ISFSI and ISFSI primary alarm station, and a review of documents.
b. Observations and Findings When all of the spent fuel was removed from the SFP and transferred to the ISFSI, the security and operations control functions shifted from the decommissioning site to the ISFSI site. The site and fuel-in-transit security plans were discontinued and only the ISFSI security plan is implemented. The ISFSI section of the Emergency Plan is also fully implemented. The Maine Yankee control room and security central alarm station had provided or coordinated certain site activities and functions including medical and fire emergency response, emergency plan notifications, the operational systems tagging program, the combustible work permitting program, fire alarm monitoring, and CR initial receipt and processing. Most of these activities are now coordinated or performed by the staff in the ISFSI primary alarm station. Some functions, such as the issue of combustible work permits, are coordinated by the decommissioning project staff. Maine Yankee staff has installed new equipment, modified procedures, and conducted training to effect this transition. A new phone system, with new phone numbers is now in use at the ISFSI; however, current phone numbers, including the control room, will remain operable until the Administration Building is demolished. The plant page system has been eliminated from the active decommissioning site area and replaced with portable radios.
On February 27, 2004, Maine Yankee completed the transfer of all spent fuel from their SFP to dry cask storage at their nearby ISFSI. On February 26, 2004, in anticipation of this final transfer, Maine Yankee had indicated that it would transition from its decommissioning security plan to its ISFSI security plan as soon as the last canister of spent fuel was placed at the ISFSI. NRC staff determined that because the May 23, 2002, Order for Interim Safeguards and Security Compensatory Measures for MYAPC was still in place, this change could not be made without specific termination of this Order. On February 27, 2004, NRC and Maine Yankee staffs executed the exchange of correspondence to appropriately terminate the May 23, 2002, Order.
c. Conclusion Maine Yankee staff implemented essential physical and procedural changes and provided training to effect the transition of its operations and security staff activities from its decommissioning site to full-scale operations at the ISFSI. NRC and Maine Yankee staffs executed the exchange of correspondence to appropriately terminate the May 23, Enclosure
2002, Order for Interim Safeguards and Security Compensatory Measures for MYAPC.
No findings of significance were identified.
IV. Plant Support R1 Radiation Protection & Chemistry (RP&C) Controls R1.1 Fuel Pool Water Treatment and Discharge a. Scope (IPs 83750, 86750)
The inspector reviewed the process being used for treatment and discharge of contaminated water from the SFP. Information was gathered through reviews of documents and water treatment system schematics, review of sample data, tours of the facility, interviews with cognizant personnel, and direct observations of work in progress.
b. Observations and Findings The SFP contained approximately 425,000 gallons of water contaminated with low levels of radionuclides (primarily H-3, Co-60, and Cs-137). Using a variety of existing systems and components, Maine Yankee staff assembled the Island Supply and Discharge System (ISADS) to filter and treat batches of SFP water prior to discharge. The 155,000-gallon Primary Water Storage Tank (PWST) served as a batch tank where filtered water from the SFP was collected and then processed through a series of demineralizer resins and an additional filtration unit. Because much of the Co-60 was present as very fine particulates, radwaste staff added a polymer flocculating agent to the water in the PWST to cause the fine particulates to clump together and thus be large enough to collect on the filter media. Frequent filter media changes were needed to control the radiation dose rate from the filter housing.
Following sufficient processing through the ISADS, the contents of the PWST were recirculated equivalent to a minimum of three batch volumes, then sampled and analyzed for radiological and environmental parameters (oil and grease and total suspended solids). The sample was split with the NRC and the State of Maine for confirmatory analyses. Radiological sample results for the initial water discharge and subsequent releases will be reported in a future inspection report once all samples are analyzed and data is received. Water discharge is through the existing wastewater discharge outfall into the Back River.
c. Conclusion Maine Yankee assembled a water treatment system for effectively filtering and processing contaminated water from the SFP. Processed water is sampled and then discharged through an existing radiation monitor and discharge pathway. Confirmatory samples of processed water will be analyzed by the NRCs contractor (ORISE) and reported in a subsequent inspection report. No findings of significance were identified.
R1.2 Review of Condition Reports Enclosure
a. Scope (IPs 83750, 40801)
The inspectors reviewed selected CRs related to radiation protection (RP) activities.
Information was gathered through review of records and discussions with cognizant personnel.
b. Observations and Findings The inspectors reviewed selected CRs where the Radiation Protection Department was assigned as the responsible department. Corrective actions were completed in a timely manner and appeared to be thorough in addressing the identified issues. CR-04-16, Failure to Follow Procedure Requirements for the Response Checking of RP Instrumentation, documents the failure to perform RP instruments performance tests and inaccurate records regarding these checks.
Maine Yankee Technical Specification 5.6.1 "Radiation Protection Program," states that
"Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
Procedure PMP 6.4, "Radiation Protection Instrumentation Program" section 5.4.13, lists one of the responsibilities for Radiation Protection Instrument Technicians as: Perform source checks on RP instruments. Generate clear and legible records of instrument performance tests. Procedure PMP 6.4.6, "Radiation Protection Instruments Performance Tests" section 6.2.1.a., states, in part, that ...instrument performance checks shall be performed daily when in use: and this performance check is applicable for portable survey instruments and section 6.2.2.a. requires, in part, that the technician
... update the source check in accordance with PMP 6.4.5, Equipment Control and Utilization Package.
Contrary to these procedural requirements, at a minimum, on February 10, 2004, the following procedural non-compliances were identified: (1) instrument performance checks for portable survey meters were apparently not performed and (2) inaccurate records were apparently created regarding these checks. These are considered apparent violations of NRC requirements with respect to Technical Specification 5.6.1, Radiation Protection Program. (AV 05000309/2004001-01 and AV 05000309/2004001-02)
Enclosure
c. Conclusion Review of CRs related to RP department issues found corrective actions to be completed within procedural time requirements and thoroughly addressed the identified issues. Two apparent NRC violations were self-identified by the CR process regarding the apparent failure to follow procedural requirements for the response checking of RP instrumentation and inaccurate records were apparently created regarding these checks. NRC has not completed its evaluation of these apparent violations and will inform Maine Yankee of any enforcement action separately.
R1.3 Review of Final Status Survey Records a. Scope (IP 37801)
The inspectors reviewed selected Final Status Survey (FSS) records including instrument calibration and technician training records. The inspectors had also reviewed documents relating to the licensees March 15, 2004, submission of a license amendment request for the release of non-ISFSI lands from the license. Information was gathered through review of records, review of documents submitted as part of the license amendment, tours of the facility, and discussions with cognizant personnel.
b. Observations and Findings A primary focus of the inspectors was the review of FSS records relevant to Maine Yankee FSS in the Containment Building. The inspectors review included records for the calibration of instruments used for FSS and records documenting training for health physics technicians performing FSS. The inspectors found the training and calibration records to be generally acceptable; however, a concern was noted related to the training status of three HP technicians on the latest revision of PMP 6.7.1, FSS Procedure for Structures, Systems, and Soils. The licensee stated that although the three health physics technicians had not completed training on the current PMP 6.7.1, they had not performed any surveys that would have required this information. An inspector follow-up item was opened to complete review of this issue. (IFI 05000309/2004001-03)
On March 15, 2004, Maine Yankee (MY) submitted a license amendment request for the Release of Non-ISFSI Site Land from the jurisdiction of its license. Attachment 4 of the amendment request contained Final Status Survey (FSS) release records for 10 survey units; FA-1700-SU-1 through FA-1700-SU-9, and FC-0300-SU-1. MY requested that the NRC staff review the release records and provide preliminary feedback on the format and content of the release records during the May 24-28, 2004, NRC inspection at MY.
License Condition 2.B(10)(i) of the MY Facility Operating License No. DPR-36 states, in part, that the licensee may make changes to the License Termination Plan (LTP) without prior approval provided the proposed changes do not: (a) require Commission approval pursuant to 10 CFR 50.59; ...(d) increase the radioactivity level, relative to the applicable derived concentration guidelines level, at which an investigation occurs.
Enclosure
10 CFR 50.59 states, in part, that a licensee shall obtain a license amendment... if a change would result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. The FSAR was updated by the MY LTP.
The staff determined that contrary to License Condition 2.B.10(i) and LTP Section 1.4, MY increased the DGCL EMC without NRC approval. MY used a 10 CFR 50.59 evaluation to change the equation used to calculate the basement concrete Area Factors [Equation (19)]. LTP Revision 3, Section 5.6.3 discusses the requirements for Elevated Measurement Comparison and Section 6.8.1 requires Equation (19) to determine the Area Factors. MY added new Equation (20) that allows for larger area factors and thus increases the Derived Concentration Guideline Level for Elevated Measurement Comparison (DCGLEMC ) for the basement contaminated concrete.
Examples of the increases include: 1) Release Record FA-1700-01 - DCGL EMC from 144,000 dpm/100cm2 to 2.25E6 dpm/100cm2, , 2) Release Record FA1700-02 -
DCGLEMC from 90,000 dpm/100cm2 to 5.92 E8 dpm/100cm2 , 3) Release Record FA1700-04 - DCGLEMC from 90,000 dpm/100cm2 to 5.92 E8 dpm/100cm2 , 4) Release Record FA1700-05 - DCGLEMC from 91,260 dpm/100cm2 to 2.08 E9 dpm/100cm2.
Further, the 10 CFR 50.59 evaluation failed to: 1) identify that MYs proposed change would require NRC approval in accordance with License condition 2.B.10(i), 2) include an As Low As Reasonably Achievable (ALARA) evaluation consistent with LTP Section 4.4 and the requirements of 10 CFR 20.1402, and 3) determine any limitations for the number of elevated measurements in accordance with LTP Section 6.8.1 which states, it is not expected that a large number of elevated areas will remain.
The staff noted that the MY 10 CFR 50.59 evaluation checklist for the proposed change to the LTP acknowledged that the proposed change would have an adverse effect on the Data Quality Objective (DQO) process primary input. The MY evaluation further stated, The area factor is a Data Quality Objective (DQO) process primary output from DQO 3 Inputs to the Decision. The affected DQO, e.g. #5 develop a decision rule, is not affected in a manner that requires revision or further action.
The use of the DQO process was less conservative than the use of the LTP, which was reviewed and approved by the NRC. The staff concluded that the licensee was required to use Section 6.8.1 and Equation (19) of the LTP, because it was explicit in the use of Area Factors. The use of revised DCGLEMC, which were increased by the licensees 10 CFR 50.59 evaluation of changes to Area Factors, is considered an apparent violation of NRC requirements with respect to License Condition 2.B.10(i) LTP Section 1.4, and 10 CFR 50.59. (AV05000309/200401-04)
c. Conclusion The inspectors reviewed selected FSS records including instrument calibration and technician training records and documents relating to the licensees March 15, 2004, submission of a license amendment request for the release of non-ISFSI lands from the license. One inspector follow-up item was opened to review training issues identified in the FSS Program. One apparent violation was identified by the staff regarding the use Enclosure
of 10 CFR 50.59 to increase the DCGLEMC without NRC approval in accordance with License Condition 2.B.10(i) and the LTP. NRC has not completed its evaluation of this apparent violation and will inform Maine Yankee of any enforcement action separately.
V. Management Meetings X1 Community Advisory Panel (CAP) Meeting On March 25, 2004, Randolph C. Ragland, NRC Region I, attended the Maine Yankee CAP Meeting. Mr. Ragland presented an overview of NRC activities and inspection findings relating to Maine Yankee and answered questions from the panel.
X2 Exit Meeting The inspectors presented inspection results to representatives of the licensees staff at the end of each inspection visit during the inspection period. On August 11, 2004, a summary of the inspection findings for the entire inspection period was presented to Mr.
Thomas Williamson, Mr. James Connell and others. Licensee representatives acknowledged the inspection findings.
Enclosure
PARTIAL LIST OF PERSONS CONTACTED Licensee and Contractor Staff W. Ball, Director, Operations - ISFSI R. Benner, Director, Decommissioning L. Brown, Manager Safety J. Connell, Radiation Protection Manager S. Evans, Environmental Remediation Manager T. Feigenbaum, President J. Grant, Security Director J. Hebert, Regulatory Affairs W. Henries, Director, Engineering E. Howes, Director Public and Government Affairs L. Jewett, Assistant Operations Manager M. Meisner, Chief Nuclear Officer E. Mercer, Radiological Engineering Supervisor J. Niles, Manager, Operations & Maintenance J. Packer, Final Site Survey G. Pillsbury, Engineer - Final Site Survey M. Readinger, Manager, Radwaste T. Shippee, QPD Manager M. Whitney, Licensing T. Williamson, Director NSRA P. Woodhams, Corrective Action Coordinator State of Maine P. Dostie, Maine Nuclear Safety Inspector INSPECTION PROCEDURES USED IP 36801: Organization, Management & Cost Controls IP 37801: Safety Reviews, Design Changes, and Mods at PSRs IP 40801: Self-Assessment, Auditing, and Corrective Actions IP 60855: Operation of an ISFSI IP 71801: Decommissioning Performance and Status Review IP 81700: Physical Security Assessment IP 83750: Occupational Radiation Exposure IP 83801: Inspection of Final Status Surveys IP 84750: Radwaste Treatment and Effluent & Environmental Monitoring IP 86750: Solid Radwaste Management & Transportation of Radioactive Material Attachment
A-2 ITEMS OPENED, CLOSED, AND DISCUSSED Items Opened: AV 05000309/2004001-01: Failure to Follow Procedure Requirements for the Response Checking of RP Instrumentation AV 05000309/2004001-02: Inaccurate Records Created Regarding Response Checks of RP Instrumentation IFI 05000309/2004001-03: Training status of three health physics technicians on the latest revision of PMP 6.7.1" AV05000309/2004001-04:: Use of 10 CFR 50.59 to increase the DCGLEMC without NRC approval in accordance with the LTP Items Closed: None Items Discussed: None LIST OF ACRONYMS USED ALARA As Low As is Reasonably Achievable AF Area Factor CAP Community Advisory Panel CFR Code of Federal Regulations cpm counts per minute CR Condition Report DCGLW Derived Concentration Guideline Level (average for wide areas)
DCGLEMC Derived Concentration Guideline Level Elevated Measurement Comparison DNMS Division of Nuclear Materials Safety dpm/100 cm2 disintegrations per minute per 100 square centimeters ESSAP Environmental Survey & Site Assessment Program FSS Final Status Survey IP Inspection Procedure ISADS Island Supply and Discharge System ISFSI Independent Spent Fuel Storage Installation LTP License Termination Plan MARSSIM Multi-Agency Radiation Survey & Site Investigation Manual mR milliRoentgens MY Maine Yankee MYAPC Maine Yankee Atomic Power Company NMSS Office of Nuclear Materials Safety and Safeguards NRC Nuclear Regulatory Commission ORISE Oak Ridge Institute for Science and Education PDR Public Document Room pCi/g picocuries per gram PWST Primary Water Storage Tank Attachment
A-3 RP Radiation Protection RPC Radiation Protection and Chemistry SPF Spent Pool Fuel Attachment