ML041690017
| ML041690017 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 06/16/2004 |
| From: | John Hickman NRC/NMSS/DWMEP/DD |
| To: | Kacich R Yankee Atomic Electric Co |
| References | |
| -RFPFR, TAC L52095 | |
| Download: ML041690017 (11) | |
Text
June 16, 2004 Mr. Richard M. Kacich, President Yankee Atomic Electric Company 19 Midstate Drive, Suite 200 Auburn, MA 01501
SUBJECT:
YANKEE (ROWE) NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE TERMINATION PLAN (TAC NO.
L52095)
Dear Mr. Kacich:
By letters dated November 24, 2003, December 10, 2003, December 16, 2003, January 19, 2004, January 20, 2004, February 2, 2004, February 10, 2004, and March 4, 2004, Yankee Atomic Electric Company submitted a License Termination Plan and an application to amend its license to incorporate a new license condition addressing the license termination plan (LTP) for the Yankee (Rowe) Nuclear Power Station. The new license condition would document the date of NRC approval of the LTP and provide criteria to determine the need for NRC approval of changes to the approved LTP. The Nuclear Regulatory Commission staff has reviewed the information provided and has determined that additional information is required as identified in the Enclosure.
We held a meeting on June 9, 2004, to discuss these questions with your staff. Please provide a response at the earliest practical date to support our continued review of the application.
Please contact me at (301) 415-3017, if you have any other questions on these issues.
Sincerely,
/RA/
John B. Hickman, Project Manager Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.50-029
Enclosure:
Request for Additional Information cc w/encl: See next page
June 16, 2004 Mr. Richard M. Kacich, President Yankee Atomic Electric Company 19 Midstate Drive, Suite 200 Auburn, MA 01501
SUBJECT:
YANKEE (ROWE) NUCLEAR POWER STATION - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE TERMINATION PLAN (TAC NO.
L52095)
Dear Mr. Kacich:
By letters dated November 24, 2003, December 10, 2003, December 16, 2003, January 19, 2004, January 20, 2004, February 2, 2004, February 10, 2004, and March 4, 2004, Yankee Atomic Electric Company submitted a License Termination Plan and an application to amend its license to incorporate a new license condition addressing the license termination plan (LTP) for the Yankee (Rowe) Nuclear Power Station. The new license condition would document the date of NRC approval of the LTP and provide criteria to determine the need for NRC approval of changes to the approved LTP. The Nuclear Regulatory Commission staff has reviewed the information provided and has determined that additional information is required as identified in the Enclosure.
We held a meeting on June 9, 2004, to discuss these questions with your staff. Please provide a response at the earliest practical date to support our continued review of the application.
Please contact me at (301) 415-3017, if you have any other questions on these issues.
Sincerely,
/RA/
John B. Hickman, Project Manager Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.50-029
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION PUBLIC Central File DWM r/f NMSS r/f Docket File 50-29 ACRS/ACNW OGC (Smith/Kannler)
JGreeves JHickman RBellamy, RI JWray, RI ML
- See Previous Concurrence OFFICE DCD/PM DCD/LA DCD/SC DCD/D NAME JHickman CBurkhalter*
CCraig*
DGillen DATE 06/09/2004 06/07/2004 06/07/2004 06/16/2004 OFFICIAL RECORD COPY
Yankee (Rowe) Nuclear Power Station cc:
Mr. Richard M. Kacich, President Yankee Atomic Electric Company 19 Midstate Drive, Suite 200 Auburn, MA 01501 Mr. Greg A. Maret, Vice President of Decommissioning Yankee Atomic Electric Company 19 Midstate Drive, Suite 200 Auburn, MA 01501 Gerry van Noordennen, Regulatory Affairs Manager Yankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367 James A. Kay, Principal Licensing Engineer c/o Framatome ANP 400 Donald Lynch Boulevard Marlborough, MA 01752 Mr. Robert Capstick, Director of Government Affairs Yankee Atomic Electric Company 19 Midstate Drive, Suite 200 Auburn, MA 01501 Mr. Frank Helin, Decommissioning Director Yankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367 Mr. Frederick Williams, ISFSI Operations Manager Yankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367 Mr. Greg Babineau, Site Closure Implementation Manager Yankee Atomic Electric Company 49 Yankee Road Rowe, MA 01367 Kelley Smith Communication Manager/Yankee Rowe Community Advisory Board 19 Midstate Drive Auburn, MA 01501 Alice Carson, RSCS, Inc.
12312 Milestone Manor Lane Germantown, MD 20876 Gerald Garfield, Esq.
Day, Berry & Howard City Place 1 Hartford, CT 06103 Ms. Leslie Greer Assistant Attorney General Commonwealth of Massachusetts 200 Portland Street Boston, MA 02114 Robert Walker, Director Radiation Control Program Massachusetts Department of Public Health 305 South Street Boston, MA 02130 Mr. James B. Muckerheide Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 Edward Flynn, Secretary Massachusetts Executive Office of Public Safety One Ashburton Place Room 2133 Boston, MA 02108
June 2004 Yankee (Rowe) Nuclear Power Station cc:
Peggy Sloan, AICP Franklin Regional Council of Governments 425 Main Street, Suite 20 Greenfield, MA 01301-3313 David OBrien, Commissioner Vermont Department of Public Service 120 State Street, Drawer 20 Montpelier, VT 05602 Amy Ignatius, Executive Director New England Conference of Public Utility Commissioners, Inc.
One Eagle Square, Suite 514 Concord, NH 03301 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Diane Screnci, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Marv Rosenstein Chief, Chemicals Management Branch Office of Ecosystem Protection U.S. Environmental Protection Agency One Congress Street, Suite 1100, Mail Code CPT Boston, MA 02114 Mr. Anthony Honnellio U.S. Environmental Protection Agency Region 1 One Congress Street, Suite 1100, Boston, MA 02114-2023 Mr. Jeff Fowley Office of Regional Counsel U.S. Environmental Protection Agency One Congress Street, Suite 1100, Mail Code RAA Boston, MA 02114 Ms. Bonnie Gitlin Radiation Protection Division Office of Radiation and Indoor Air Office of Air and Radiation U.S. Environmental Protection Agency Ariel Rios Building, Mail Code 66081 1200 Pennsylvania Avenue, NW Washington, DC 20460 Mr. Phillip Newkirk Radiation Protection Division Office of Radiation and Indoor Air Office of Air and Radiation U.S. Environmental Protection Agency Ariel Rios Building, Mail Code 66081 1200 Pennsylvania Avenue, NW Washington, DC 20460 Citizens Awareness Network P.O. Box 83 Shelborne Falls, MA 01370 Jonathan M. Block Attorney at Law Main Street P.O. Box 566 Putney, VT 05346-0566
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE TERMINATION PLAN YANKEE (ROWE) NUCLEAR POWER STATION DOCKET NO.50-029 1.
(Page 5-1) Section 5.1, second paragraph, states that advanced survey technologies may be used to conduct radiological surveys that can effectively scan 100% of the surface.... On page 5-17, it is noted that less than 100% coverage of survey units may occur. Text in Section 5.1 should state that less than 100% coverage may occur for Class 2 and 3 survey units.
Basis: LTP sections should be consistent with each other.
2.
(Page 5-1) Section 5.1, second paragraph, discusses advanced survey technologies.
Technical evaluations will be developed. Confirm that NRC will be given the opportunity to review the technical evaluations and you will provide prior notification to the NRC before the use of alternate instruments or technologies.
Basis: This information is necessary to determine if the survey method is adequate to meet the decommissioning requirements in Subpart E of 10 CFR 20.
3.
(Page 5-6) In the second paragraph under the bullet Specify Tolerable Limits on Decision Errors, change the last sentence to The following statement will [rather than may] be used as the null hypothesis at YNPS unless otherwise approved by the NRC:
The survey unit exceeds the release criteria. Change Section 1.6 to reflect NRC concurrence is needed to use other than this null hypothesis.
Basis: Other null hypotheses may be less robust. MARSSIM recommends using the null hypothesis as stated above. Statistical tests must ensure survey units meet the decommissioning requirements in Subpart E of 10 CFR 20.
4.
(Page 5-6) A Type I error of 0.05 (5%) is set in section 5.4.1. If double sampling is performed as proposed in Section 5.5.3.5, a smaller Type I error (e.g., 0.025) may be necessary for the initial survey design. See additional discussion in comment on Section 5.5.3.5. Please justify your proposal or revise.
Basis: Double sampling changes the Type I error. This information is necessary to determine if the statistical analysis is adequate to meet the decommissioning requirements in Subpart E of 10 CFR 20.
5.
(Page 5-7) The first paragraph of Section 5.4.2 states The process described in LTP Section 1.6 will be used to evaluate the modifications to unit classifications to determine whether prior notification by the NRC is required. As it reads currently,...prior notification by the NRC... isnt really correct since notification is done by the licensee to the NRC. Please revise by the NRC to to the NRC.
6.
(Page 5-8) Section 5.4.2, first paragraph following Table 5-1 must be consistent with Section 5.5.3.5, Re-survey. Changes are anticipated in Section 5.5.3.5 concerning subdividing survey units. Subdividing the survey units changes the statistical result.
Please include a requirement for NRC notification prior to subdividing survey units.
7.
(Page 5-8) Section 5.4.3 should provide the accuracy (and explanation as to the acceptability of that accuracy) of the GPS system.
Basis: Accurate survey equipment is necessary for the proper characterization and for meeting the remediation requirements in Subpart E of 10 CFR 20.
8.
(Page 5-9) Section 5.4.4, third paragraph, discusses an alternative background determination method. This method may be used only with prior NRC approval. It is not clear if this is a conservative background determination method. This should not be the general or routine method for obtaining backgrounds. Provide further technical justification or remove.
9.
(Page 5-12) Section 5.4.5.2, first paragraph after bullets, references two standard deviations above the FSS mean as a threshold to initiate an investigation. Explain the statistical basis for this threshold, and which data set the standard deviation comes from. It is not clear that the proposed threshold and associated survey(s) provide assurance equivalent to the FSS.
10.
(Page 5-12) Section 5.4.5.2, last paragraph should reference, specify, or describe the specific radiological contamination levels that are used to trigger an investigation survey.
11.
(Page 5-14) Section 5.4.6.1, last paragraph discusses insignificant radionuclides and gives a citation to 10 CFR 20. However, 10 CFR 20.1204(g)(3) pertains to calculation of internal dose for occupational exposure, and the dose is still calculated on the total activity of the mixture. NUREG-1757, Vol. 2, Section 3.3, page 3-4 has a discussion of the treatment of insignificant radionuclides concerning pathway analysis and dose for decommissioning. The treatment in the LTP should be similar to that in NUREG-1757 or a justification need to be provided.
12.
(Page 5-14) Section 5.4.6.2: may need more detail concerning DQOs for surrogate ratios. How (and how well) will ratios be determined? Will the ratio be checked to ensure it is representative during the FSS?
13.
(Page 5-15) Section 5.4.6.2, last two sentences: the contributions from all radionuclides, including insignificant contributors, must be accounted for in demonstrating compliance per NUREG-1757. Delete the last sentence or justify. See question 11.
14.
(Page 5-16) Section 5.5, second bullet at bottom of page, gives ranges of scanning coverage for Class 2 survey units. Provide the methodology for deciding what the coverage will actually be for a Class 2 survey unit.
15.
(Page 5-17) Section 5.5: the text on this page describes in a general way how advanced survey techniques will be used. When 100% of the area is covered (as in Class 1 units), and assuming an adequate MDC, the advanced survey technique provides more complete spatial coverage than discrete measurements or samples.
However, when less than 100% is covered, there will be some unsampled area.
MARSSIM traditional methodology provides coverage over 100% of the area by a random-start systematic pattern, with statistical inference. Even 100 % of Class 3 areas are sampled randomly. The proposed substitution of advanced survey techniques for both the scan and fixed measurements/sampling does not provide adequate spatial coverage for Class 2 and 3 areas. Please provide further clarification on how advanced survey techniques will be conducted on Class 2 and 3 areas to ensure that 100% of the area is subject to random sampling.
16.
(Page 5-17) The last bullet discusses surveys that combine advanced techniques with traditional methods. Provide more detail as to how the number of traditional measurements/samples will be determined for the areas not assessed with the advanced technique, and how statistical tests will be performed.
17.
(Page 5-18) Section 5.5.1.1 sets at 0.05. Note that the double sampling proposed in Section 5.5.3.5 will increase to greater than 0.05. If the licensee retains the provision for double sampling, should be set to 0.025. See question # 4.
18.
(Page 5-19) Section 5.5.1.2, sentence after the two bullets: as noted in the comment for page 5-9, Section 5.4.4, parameters for backgrounds should not be taken from the survey area. Add a sentence emphasizing that the reference areas will not be in the survey area unless NRC approval is obtained.
19.
(Page 5-24) In the paragraph following Equation 5-15, it is stated that if a method of calculating MDC is different than MARSSIM, a technical evaluation will be available for NRC inspection. Notification to the NRC should be made prior to implementation.
Basis: Since the MDC is a key parameter for survey design, the method to calculate MDC should not be changed without NRC concurrence. Calculating MDC in an approved and defensible manner is necessary to ensure the survey design is adequate to meet the decommissioning requirements in Subpart E of 10 CFR 20.
20.
(Page 5-26) Section 5.5.1, last paragraph: the accuracy and suitability of the GPS system should be provided somewhere. (Essentially the same comment as for Section 5.4.3, page 5-8.) See question # 7.
21.
(Page 5-27) Section 5.5.2, first paragraph at top of page: Specify the number, percentage, or other DQO that quantifies how many samples will be taken to confirm the radionuclide mix.
22.
Page 5-28) Section 5.5.3.3 discusses remediation. Provide examples of other reasons that cause removal of materials that would not be considered remediation.
23.
(Page 5-28) Section 5.5.3.3 does not discuss the possibility that remediation may also be necessary to meet the requirement for the average concentration above background to be less than the DCGLW, not just those spots above the DCGLEMC. Please address this issue.
24.
(Page 5-29) Section 5.5.3.4 allows subdividing a survey unit and reclassifying the parts.
While a whole unit could be re-classified from a less restrictive to more restrictive classification without prior NRC approval, subdividing a failed unit has a potential impact on the Type 1 decision error (as well as raising questions concerning the original classification methodology) and so should be done only with prior NRC notification.
25.
(Page 5-29) Section 5.5.3.5 proposes a re-survey methodology that is essentially double sampling. Double sampling can double the Type I decision error. In some cases, double sampling may be acceptable if a smaller Type 1 error was used for the initial survey design. If the original survey uses a Type 1 error of 0.05, the proposed additional sampling of the subdivided cleaner area would result in an increase of the Type I error to greater than 0.05 and would require NRC approval. See also questions 4 and 17.
26.
(Page 5-29) Section 5.5.3.5, last paragraph: This case (remediation of a small area of a Class 1 survey area and subsequent limited survey) could only be performed if the survey unit passed the Wilcoxon or Sign test.
27.
(Page 5-32) Section 5.6.1.3, last paragraph: NRC notification should be made prior to using advanced survey technologies. See also question #2.
28.
(Page 5-32) Section 5.6.1.4: NRC notification should made prior to using advanced survey technologies. See also question #2.
29.
(Page 5-32) Section 5.6.1.4, last paragraph: While a calibration using one geometry may be extended to others by modeling, the requirement that the measured configuration matches the assumed (modeled) configuration exists. Often, much more data is needed concerning the materials close to the source (such as shield densities, thicknesses, and composition). A source distribution is also assumed. These factors and associated quality assurance will need to be addressed in a technical support document submitted to the NRC prior to implementation.
30.
(Page 5-32) Section 5.6.1.5: A nominal or minimum sample size (mass) and depth should be specified, as well as procedural details such as removal of extraneous material and handling.
31.
(Page 5-35) Section 5.6.2.3: adjusted data must be documented and noted as such in the FSS Report. The technical basis and rationale for the adjustment must be provided for review.
32.
(Page 5-35) Section 5.6.2.4: The statement Instruments and methods used for field measurements will be capable of meeting the investigation level in Table 5-2" is less limiting than the third paragraph on page 5-17 (10-50% of the DCGL). Please resolve the discrepancy.
33.
(Page 5-38) Section 5.6.2.4.4, first paragraph, second sentence: If larger NaI detectors...are used, then the scan MDC will be computed using the methods of
...MARSSIM. Please commit to documenting the computation of the scan MDC.
34.
(Page 5-38) Section 5.6.2.4.4, second paragraph, last sentence: Demonstrate the alternate method of determining the scan MDC is conservative.
35.
(Page 5-44) Section 5.6.3.2.2 states that 25 locations in the industrial area will be sampled initially for subsurface contamination. Please provide the rationale for this number.
36.
(Page 5-44) Section 5.6.3.2.2 states a minimum of 5% of the routine subsurface samples will be analyzed for hard-to-detect radionuclides. For other samples (e.g.,
surfaces soils), what fraction will be analyzed for hard-to-detect radionuclides? Is there additional information to support this percentage?
37.
(Page 5-44) Section 5.6.3.2.2 indicates that 3-meter subsurface samples will be homogenized over the entire depth of the core. Homogenizing over 1-meter lengths or less provides more information on the vertical distribution of radionuclides. Please justify 3 meter homogenization.
38.
(Page 5-46ff) Section 5.7 addresses only the traditional type of surveys. It is not clear how data from traditional methods combined with advanced methods, or data from advanced methods alone, will be evaluated.
39.
(Page 5-50) Section 5.7.2, second paragraph from top: elaborate on which actual values will be assigned to less than MDC data for the Sign Test.
40.
(Page 5-51) Section 5.7.5, second paragraph references MARSSIM Sections I.9 and I.10 concerning retrospective power analyses.Section I.10 presents spreadsheet formulas and does not deal with power analyses.
41.
(Page 5-51) Section 5.7.5, last sentence: Depending on the survey design, a new survey may also increase the Type 1 error and would, therefore, also require concurrence by the regulator. Please revise the statement accordingly or justify why not.
42.
(Page 4-2) Section 4.2.1: Please commit to NRC notification prior to backfill of excavations or justify why not.
43.
(Page 4-3) Section 4.2.3: Is no remediation of groundwater still true given more data on the tritium plume?
44.
(Page 4-4) Section 4.3.2: last paragraph: provide justification for (or the source of) the statement The ALARA criterion is met by performing the action and not necessarily by achieving results below the specified action level, and also the next sentence.
45.
(Page 4A-3) Table 4A-1 change parameter R to r.
46.
(Page 4A-5) last paragraph: Additional discussion is needed concerning meeting ALARA criteria by performing a cleanup action as opposed to achieving cleanup goals.
47.
HSA Section 8 references: provide Ref. 15 (YRC-1178) 48.
HSA Vol. 1 (page 7-4) Section 7.3 references Section 7.2.2; should this be 7.3.2?
49.
HSA Vol. 1 (page 7-6) paragraph preceding Section 7.3.1:
In examining the SOF values on Table 7-4, it is evident that the use of the interim DCGLs would not result in any reclassifications for all class 2 and 3 survey areas given the reasonably close agreement between these DCGLs and the low SOF values shown for the survey areas. Therefore, modification of the comparison basis to the final proposed DCGLs is not needed since this data provides ample substantiation of the classification performed only by historical basis.
Comment: More discussion is needed on possible reclassification due to smaller DCGLs. The criteria for classification are not presented quantitatively, so it is not evident that the smaller final DCGLs do not cause some previously Class 3 areas to be Class 2. In addition contributions from tritium and Sr-90 must be added if present. An additional concern is that the dose contribution from insignificant radionuclides may not have been factored in (see comment for page 5-14, Section 5.4.6.1). Some areas that are classified as Class 3 (for example, OOL-01, OOL-03, and OOL-08) will have a maximum SOF that is close to or greater than 0.5. Table 7.4 should be augmented (or a new table created) with SOFs based on the final DCGLs and accounting for dose from insignificant radionuclides, tritium and Sr-900. (Conversely, subtraction of environmental background for Cs-137 will lower the SOF.)
50.
HSA OOL-02, p.4, current status ff, discusses OOL-08... need OOL-02 discussion.
51.
The licensee should provide groundwater potentiometric maps of the water-bearing units that have been or potentially may be impacted by site-generated radionuclides.
The licensee should indicate groundwater flow directions on these maps and provide information on the hydraulic gradient. Additional potentiometric maps may need to be developed to represent seasonal or climatic changes in the water levels if these changes are significant.
52.
The extent of the H-3 groundwater plume and of other potential site-generated radionuclide plumes should be adequately characterized, including horizontal and vertical dimensions and magnitude of radionuclide concentrations. The characterization of the plume(s) should also cover the development of hydraulic conductivity and storage values for the different water-bearing units.
53.
The licensee should discuss whether site-generated radionuclides have moved offsite (i.e., reached Sherman Pond, Deerfield River, or other locations) or discuss the potential for site-generated radionuclides to move offsite. The fate and transport of the radionuclides in the groundwater should be evaluated and discussed. The licensee should also provide the rates of groundwater transport and an estimate of the time for radionuclides in the groundwater to travel offsite.
54.
The relationship between groundwater and surface water should be examined and discussed.
55.
The only groundwater sample results for site-generated radionuclides in the LTP are for H-3, gross alpha, and gross beta (Table 2-7). The concentrations and dates of sample collection for all site-generated radionuclides in the groundwater and surface water should be provided.
Basis (51-55): The extent of site-generated radionuclides in the groundwater and surface water needs to be adequately characterized to understand the potential dose that these radionuclides may produce. The existing H-3 groundwater plume and other potential site-generated radionuclide groundwater plumes should be defined with respect to length, width, depth, and magnitude of concentration. The hydrogeologic features at the site that impact the ability of radionuclides in the groundwater and surface water to migrate should also be characterized. These data are needed to understand the impact, the potential dose, of site-generated radionuclides on humans.
56.
The dose contribution of the H-3 plume should be evaluated. Based on the results of the analysis, either a derived concentration guideline level (DCGL) can be created or, if the dose is less than 0.025 mSv/y (2.5 mrem/y), the H-3 dose contribution can be treated as insignificant as described in Section 3.3 of NUREG-1757, Volume 2. The dose contribution, as described in the guidance, would still count as part of meeting the dose limit.
Basis: The license termination rule is based on an all-pathways dose analysis. Data from the site shows elevated concentrations of H-3 in portions of the groundwater.
57.
The LTP should be revised in Chapter 6 to include a common table displaying the DCGLs for soil, surfaces, and below-grade concrete. Additionally, the DCGLs for elevated measurements should be included in the revised Chapter 6.
Basis: Currently, the site-wide average DCGLs and the elevated measurements DCGLs are contained in a number of separate documents that were provided as support to the LTP between December 2003 and March 2004. Consolidation of the derived limits would facilitate review and future inspection against the derived limits.
Please provide copies of the following documents:
1.
Copies of Franklin County Council of Governments comments on the LTP (and YAEC responses). Please submit these as soon as possible, as we would like to review them before the public meeting.
2.
One copy of the November 2003 Public Archeology Laboratory report, Archeological Reconnaisance Survey, Archeological Resources Management Plan, Yankee Nuclear Power Station.
3.
Copies of communications to/from Massachusetts Historical Commission, including: July 11, 2003 letter to MHC from ERM and August 18, 2003 response from MHC to ERM.
4.
Copies of communications to/from the Division of Fisheries and Wildlife or the Fish and Wildlife Service concerning endangered species.
5.
Site Characterization Status Report when available.
6.
Copy of MEPA certificate when available.
7.
Unredacted copy of the information submitted to FERC in reference 7-2.