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Category:Letter
MONTHYEARML23342A0972024-01-0909 January 2024 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan CY-23-014, Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI2023-12-0404 December 2023 Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI ML23124A2012023-04-20020 April 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2022 CY-23-006, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2023-03-0606 March 2023 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-23-007, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2023-03-0606 March 2023 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste ML22340A4922023-02-24024 February 2023 Closeout Letter to Connecticut Yankee Regarding 2018 and 2021 Updated DFPs for Haddam Neck Plant ISFSI CY-23-004, Independent Spent Fuel Storage Installation, Property Insurance Coverage2023-01-17017 January 2023 Independent Spent Fuel Storage Installation, Property Insurance Coverage CY-23-003, Independent Spent Fuel Storage Installation, Nuclear Liability Insurance Coverage2023-01-17017 January 2023 Independent Spent Fuel Storage Installation, Nuclear Liability Insurance Coverage CY-23-002, Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments2023-01-0505 January 2023 Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments CY-23-001, Independent Spent Fuel Storage Installation, Report of 10 CFR 50.59 Changes, Tests, and Experiments2023-01-0505 January 2023 Independent Spent Fuel Storage Installation, Report of 10 CFR 50.59 Changes, Tests, and Experiments IR 07200039/20224012022-10-0505 October 2022 Connecticut Yankee Atomic Power Company - NRC Independent Spent Fuel Storage Security Inspection Report No. 07200039/2022401 CY-22-012, Independent Spent Fuel Storage Installation, Supplemental Information for the Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2022-08-0303 August 2022 Independent Spent Fuel Storage Installation, Supplemental Information for the Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan CY-22-010, Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation, Formal Announcement of New ISFSI Manager2022-05-25025 May 2022 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation, Formal Announcement of New ISFSI Manager CY-22-006, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 20212022-04-25025 April 2022 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2021 CY-22-004, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2022-03-14014 March 2022 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-22-003, and Independent Spent Fuel Storage Installation, Decommissioning Funding Assurance Status Report2022-03-14014 March 2022 and Independent Spent Fuel Storage Installation, Decommissioning Funding Assurance Status Report ML22011A1352022-01-31031 January 2022 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan CY-22-001, Independent Spent Fuel Storage Installation - Nuclear Liability Insurance Coverage2022-01-20020 January 2022 Independent Spent Fuel Storage Installation - Nuclear Liability Insurance Coverage CY-22-002, Independent Spent Fuel Storage Installation - Property Insurance Coverage2022-01-20020 January 2022 Independent Spent Fuel Storage Installation - Property Insurance Coverage CY-21-015, Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2021-12-10010 December 2021 Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan CY-21-011, Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI2021-12-0101 December 2021 Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI ML22075A2382021-12-0101 December 2021 Biennial Update to the Haddam Neck Plant Updated Final Safety Analysis Report CY-21-013, Biennial Update to the Haddam Neck Plant License Termination Plan2021-12-0101 December 2021 Biennial Update to the Haddam Neck Plant License Termination Plan CY-21-014, Independent Spent Fuel Storage Installation - Adoption of Amendment 8 of NAC-MPC Certificate of Compliance No. 72-1025 and Canister Registration2021-11-18018 November 2021 Independent Spent Fuel Storage Installation - Adoption of Amendment 8 of NAC-MPC Certificate of Compliance No. 72-1025 and Canister Registration IR 05000213/20210012021-10-26026 October 2021 Connecticut Yankee Atomic Power Company - NRC Independent Spent Fuel Storage Installation Inspection Report Nos. 07200039/2021001 and 05000213/2021001 ML21144A2512021-04-13013 April 2021 Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2020 CY-21-006, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2021-03-0202 March 2021 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-21-005, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2021-03-0202 March 2021 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-21-003, Independent Spent Fuel Storage Installation Nuclear Liability Insurance Coverage2021-01-27027 January 2021 Independent Spent Fuel Storage Installation Nuclear Liability Insurance Coverage CY-21-004, Independent Spent Fuel Storage Installation - Property Insurance Coverage2021-01-27027 January 2021 Independent Spent Fuel Storage Installation - Property Insurance Coverage ML21012A3192021-01-13013 January 2021 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan IR 07200039/20204012020-11-20020 November 2020 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Report 07200039/2020401, Without Enclosure (Public - Cover Letter Only) ML20150A3352020-06-19019 June 2020 COVID-19 Exemption for Haddam Neck CY-20-011, Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement2020-05-14014 May 2020 Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement ML20143A0972020-04-16016 April 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2019 CY-20-007, Independent Spent Fuel Storage Installation - Formal Announcement of New Tsfst Manager2020-03-31031 March 2020 Independent Spent Fuel Storage Installation - Formal Announcement of New Tsfst Manager CY-20-004, Independent Spent Fuel Storage Installation - Funding Report for Managing Irradiated Fuel and GTCC Waste2020-03-17017 March 2020 Independent Spent Fuel Storage Installation - Funding Report for Managing Irradiated Fuel and GTCC Waste CY-20-003, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2020-03-12012 March 2020 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-20-002, Independent Spent Fuel Storage Installation, Letter Notifying NRC the Amount of Property Insurance Coverage in Force for 20202020-01-22022 January 2020 Independent Spent Fuel Storage Installation, Letter Notifying NRC the Amount of Property Insurance Coverage in Force for 2020 ML20015A5262020-01-15015 January 2020 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan ML19269C4642019-10-11011 October 2019 Letter to B. Mitchell Exemption from 10 CFR 72.212 and 72.214 for Dry Spent Fuel Storage Activities - Haddam Neck Plant Independent Spent Fuel Storage Installation CY-19-014, Independent Spent Fuel Storage Installation - Formal Announcement of ISFSI Manager'S Return2019-06-0505 June 2019 Independent Spent Fuel Storage Installation - Formal Announcement of ISFSI Manager'S Return CY-19-012, Independent Spent Fuel Storage Installation - 2018 Individual Monitoring NRC Form 5 Report2019-04-23023 April 2019 Independent Spent Fuel Storage Installation - 2018 Individual Monitoring NRC Form 5 Report ML19070A0332019-02-20020 February 2019 Letter to C. Pizzella Nuclear Regulatory Commission'S Analysis of Connecticut Yankee Atomic Power Company'S Initial and Updated Decommissioning Funding Plans for the Haddam Neck Plant Independent Spent Fuel Storage Installation CY-18-021, Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2018-12-10010 December 2018 Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan IR 05000213/20180012018-05-31031 May 2018 NRC Independent Spent Fuel Storage Installation Inspection Report Nos. 07200039/2018001 and 05000213/2018001, Connecticut Yankee Atomic Power Company, East Hampton, Connecticut Site IR 07200039/20184012018-05-17017 May 2018 Connecticut Yankee Atomic Power Company Independent Spent Fuel Storage Security Inspection Report No. 07200039/2018401 - (Cover Letter Only) CY-18-004, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2018-03-0505 March 2018 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-18-005, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2018-03-0505 March 2018 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-17-021, Independent Spent Fuel Storage Installation Formal Announcement of Change in HNP ISFSI Manager2017-09-0505 September 2017 Independent Spent Fuel Storage Installation Formal Announcement of Change in HNP ISFSI Manager 2024-01-09
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 JUN 72004 OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE Mr. Jack R. Strosnider, Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Dear Mr. Strosnider:
I am writing in response to Martin Virgilio's letter of March 5, 2004, regarding the Saxton Nuclear Experimental Corporation (Saxton) site in Liberty Township, Bedford County, Pennsylvania. The March 5 letter notified EPA that the Saxton site would have triggered an NRC consultation with EPA in accordance with the 2002 Memorandum of Understanding (MOU) entitled: "Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites" (OSWER No. 9295.8-06, signed by EPA on September 6, 2002, and NRC on October 9, 2002). This letter responds to the notification in accordance with Section V.D.I of the MOU, when NRC requests EPA's consultation on a decommissioning plan or a license termination plan, EPA is obligated to provide written notification of its views within 90 days of NRC's notice.
Mr. Virgilio's letter does not constitute a Level 1 consultation as specified in the MOU because a License Termination Plan (LTP) had already been issued for the site. NRC initiated the consultation on this site in the spirit of the MOU. EPA is providing its views in a manner equivalent to what we expect to provide for in future Level 1 consultations, similarly, in keeping with the spirit of the MOU.
The views expressed by EPA in this letter regarding NRC's decommissioning are limited to discussions related to the MOU. The comments provided here do not constitute guidance related to the cleanup of sites under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) .' EPA's views on the matters addressed by this letter were developed from information furnished by NRC in the March 5 letter, other materials provided by NRC, and staff discussions.
IPlease see the memorandum entitled: "Distribution of Memorandum of Understanding between EPA and the Nuclear Regulatory Commission" (OSWER No. 9295.8-06a, October 9, 2002) which includes guidance to the EPA Regions to facilitate Regional compliance with the MOU and to clarify that the MOU does not affect CERCLA actions that do not involve NRC (e.g., the MOU does not establish cleanup levels for CERCLA sites). This memorandum may be found on the Internet at: http://www.epa.gov/superfund/resources/radiation/pdf/transmou2fin.pdf.
EPA Consultation Views Today's response is limited to those matters that initiated NRC's request for consultation in its letter of March 5. NRC initiated this consultation because the derived concentration guideline levels (DCGLs) in the License Termination Plan (LTP) exceed the MOU trigger values for two radionuclides for soil. It is EPA's understanding that DCGLs are generally developed for all radionuclides that a licensee was permitted by NRC to use. It is also our understanding that many of these radionuclides may not be present in the media (soil) discussed in this letter, and that the remediation activities associated with NRC's decommissioning process are likely to significantly decrease below the DCGLs the residual levels of those radionuclides that are present.
Soil: Land use NRC triggered the consultation for soil on the basis of DCGLs for 5 radionuclides in the LTP exceeding the residential Table I values in the MOU. Table 1 contains trigger values for both residential and industrial/commercial land use. It is EPA's understanding that the future land use for portions of this site with significant soil contamination are likely to continue to be industrial use after NRC decommissions. At CERCLA sites, EPA generally uses the guidance "Land Use in the CERCLA Remedy Selection Process" (OSWER Directive No. 9355.7-04, May 25, 1995) to determine what is a reasonably anticipated land use. This guidance document may be found on the Internet at: http://www.epa.gov/superfund/resources/landuse.pdf.
As your letter states, NRC is planning to release the site for unrestricted use. In EPA's view NRC should consider determining if the reasonably anticipated land use for the site is
- industrial/commercial. If the future use of the site is reasonably anticipated to be industrial, rather than residential, it is more likely that the site will not exceed Table 1 trigger values in accordance with that land use.2 Ensuring continuance of a restricted land use, such as industrial, however, is likely to involve the use' of institutional controls. For further information regarding how EPA selects institutional controls, see "Institutional Controls: A Site Manager's Guide to Identifying, Evaluating and Selecting Institutional Controls at Superfund and RCRA Corrective Action Cleanups" (OSWER Directive 9355.0-74FS-P, September 2000). This guidance document may be found on the Internet at:
http://www.epa.gov/superfund/action/ic/guide/guide.pdf.
Soil: Modeling The five radionuclides with Table I soil values in the MOU that NRC's DCGLs exceed at this site are based on a 1 x104 cancer risk, developed using an electronic calculator entitled:
"Radionuclide Preliminary Remediation Goals (PRGs) for Superfund." This calculator generates PRG concentrations at the 1 x 10' risk level. The PRG value at 1 x 10-6 was multiplied by 100 to derive the 1 x 104 value for Table 1 consultation triggers. (At CERCLA sites, PRGs based on cancer risk should continue to be developed at the 1 x 10' level.) The soil concentration values 2
Please note that in accordance with Section 121(c) of CERCLA EPA, when remediating a site for an industrial/commercial land use, is also likely to review the site for continued protectiveness at least every five years.
I
were developed using conservative default parameters. At most sites, higher soil concentrations corresponding to a given risk level may generally be justified using site-specific parameters. The radionuclide PRG calculation to6l may be found on the Internet at:
http://epa-prgs.oml.gov/radionuclides/.
In EPA's view, NRC should consider determining if the use of site-specific parameters were justified in modeling at this site. The use of site-specific parameters would not alter NRC's obligation to possibly trigger a future Level 2 consultation, if Table 1 soil values were found to be exceeded after the Final Status Survey (FSS). However, during a potential Level 2 consultation, if NRC is able to furnish such site-specific parameters and their rationale for allowing their use during the dose assessment for the site, such information may facilitate EPA offering its views with a more accurate estimate of the risks posed by residual contamination at the site.
Conclusion EPA staff will remain available to NRC for consultation as further plans are developed for needed remediation at the site. If you have any questions regarding this letter, please contact Stuart Walker of my staff at (703) 603-8748.
Sincerely, Michael B. Cook, Director Office of Superfund Remediation and Technology Innovation