ML050050085

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Request for Additional Information (RAI) Regarding Final Status Survey (FSS) Supplement No. 4
ML050050085
Person / Time
Site: Maine Yankee
Issue date: 01/05/2005
From: Gillen D
NRC/NMSS/DWMEP
To: Meisner M
Maine Yankee Atomic Power Co
References
Download: ML050050085 (5)


Text

January 5, 2005 Mr. Michael J. Meisner, Chief Nuclear Officer Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, Maine 04578-4922

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING FINAL STATUS SURVEY (FSS) SUPPLEMENT NO. 4 On November 17, 2004, Maine Yankee Atomic Power Company (MY) submitted Final Status Survey (FSS) Supplement No. 4, for U.S. Nuclear Regulatory Commission (NRC) review and approval. FSS Supplement No. 4 includes the following 15 survey units: FA-1400 Personnel Hatch; FA-1900 HV 7 and 9 Area; FB-0200 Control and Computer Rooms/Service Area; FB-0500 Turbine Building (4 survey units); FB-1100 Circulating Water Pump House; FB-2000 Bailey Barn; FB-2600 Warehouse 5; FB-3000 Sewage Water Treatment Plant; FC-2000 Containment Foundation Drains (embedded pipe); FD-0500 Circulating Water Piping (2 survey units); and FR-0910 Firepond and Fire Pumphouse (2 survey units).

The attachment provides the staffs comments requiring resolution before the NRC approval of FSS Supplement No.4. NRCs request for additional information is the result of: (1) missing or insufficient technical information; or (2) missing or insufficient basis for technical conclusions.

Maine Yankee is requested to provide the information identified in the attachment. A schedule for Maine Yankees resubmittal of the survey information, and NRC subsequent review, will be established during an upcoming biweekly teleconference.

Questions regarding this letter should be directed to John Buckley at 301-415-6607.

Sincerely,

/RA/

Daniel M. Gillen, Deputy Director Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-309 License No.: DPR-36

Attachment:

As stated cc: See next page

January 5, 2005 Mr. Michael J. Meisner, Chief Nuclear Officer Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, Maine 04578-4922

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING FINAL STATUS SURVEY (FSS) SUPPLEMENT NO. 4 On November 17, 2004, Maine Yankee Atomic Power Company (MY) submitted Final Status Survey (FSS) Supplement No. 4, for U.S. Nuclear Regulatory Commission (NRC) review and approval. FSS Supplement No. 4 includes the following 15 survey units: FA-1400 Personnel Hatch; FA-1900 HV 7 and 9 Area; FB-0200 Control and Computer Rooms/Service Area; FB-0500 Turbine Building (4 survey units); FB-1100 Circulating Water Pump House; FB-2000 Bailey Barn; FB-2600 Warehouse 5; FB-3000 Sewage Water Treatment Plant; FC-2000 Containment Foundation Drains (embedded pipe); FD-0500 Circulating Water Piping (2 survey units); and FR-0910 Firepond and Fire Pumphouse (2 survey units).

The attachment provides the staffs comments requiring resolution before the NRC approval of FSS Supplement No.4. NRCs request for additional information is the result of: (1) missing or insufficient technical information; or (2) missing or insufficient basis for technical conclusions.

Maine Yankee is requested to provide the information identified in the attachment. A schedule for Maine Yankees resubmittal of the survey information, and NRC subsequent review, will be established during an upcoming biweekly teleconference.

Questions regarding this letter should be directed to John Buckley at 301-415-6607.

Sincerely,

/RA/

Daniel M. Gillen, Deputy Director Decommissioning Directorate Division of Waste Management and Environmental Protection Office of Nuclear Material Safety and Safeguards Docket No.: 50-309 License No.: DPR-36

Attachment:

As stated cc: See next page DISTRIBUTION:

DWMEP r/f DCD r/f MRoberts, RI RBellamy, RI MY Distribution List ML050050085 *See previous concurrence OFFICE DCD* DCD* EPAD* DCD* DCD* DCD NAME JBuckley BWatson CMcKenney TMixon CCraig DGillen DATE 1/02/05 1/04/05 1/04/05 1/05/05 1/05/05 1/05/05 OFFICIAL RECORD COPY

Maine Yankee Atomic Power Plant Service List cc:

Thomas G. Dignan, Jr., Esquire Mr. Patrick J. Dostie Ropes & Gray State of Maine Nuclear Safety One International Place Inspector Boston, MA 02110-2624 Maine Yankee Atomic Power Company 321 Old Ferry Road Ms. Paula Craighead, Esquire Wiscasset, ME 04578-4922 State Nuclear Safety Advisor State Planning Office Mr. William Henries, Director State House Station #38 Engineering Augusta, ME 04333 Maine Yankee Atomic Power Company 321 Old Ferry Road Mr. P. L. Anderson, Project Manager Wiscasset, ME 04578-4922 Yankee Atomic Electric Company 580 Main Street Mr. Paul Bemis Bolton, MA 01740-1398 Stone & Webster Engineering & Construction c/o Maine Yankee Atomic Power Company First Selectman of Wiscasset P.O. Box 727 Municipal Building Bailey Point Road & Old Ferry Road U.S. Route 1 Wiscasset, ME 04578 Wiscasset, ME 04578 Mr. Phil Munck Friends of the Coast George E. Sansoucy P.O. Box 98 260 Ten Rod Road Edgecomb, ME 04556 Rochester, NH 03867-0823 Mr. Thomas L. Williamson, Director Mr. Mark Roberts Nuclear Safety and Regulatory Affairs U.S. Nuclear Regulatory Commission Maine Yankee Atomic Power Company 475 Allendale Road 321 Old Ferry Road King of Prussia, PA 19406 Wiscasset, ME 04578-4922 David Lewis, Esquire Mr. Jonathan M. Block Shaw Pittman Attorney at Law 2300 North Street, NW P.O. Box 566 Washington, DC 20037 Putney, VT 05346-0566 Joseph Fay, Esquire Maine Yankee Atomic power Company 321 Old Ferry Road Wiscasset, ME 04578-4922

Mr. Ted C. Feigenbaum President and Chief Executive Office Maine Yankee Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922 W. Clough Toppan, P.E., Director Division of Health Engineering Department of of Human Services

  1. 10 State House Station Augusta, ME 04333 Mr. Michael J. Meisner Chief Nuclear Officer Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922

Maine Yankee Supplement 4 - Request for Additional Information LTP Section 3.2.4 and Table 3-3 state that the Turbine Building will be demolished to three feet below grade and backfilled. FSS-RR Report No. 4 (dated November 17, 2004) states that, "[a]ll demolition activities associated with the Turbine Building have been completed," and that

"[s]urveys were performed on the foundation footprint prior to the backfill." Therefore, the surveyed areas are approximately 3 feet below grade after backfilling. LTP Section 6.6.5 states that, "[d]eep soil is defined as soil at depths greater than 15 cm." Given that the Turbine Building footprint is at an after backfill depth of 3 feet, it appears that the Surveys Units 3 and 4 should be designated as deep soil.

The staff notes that in FSS-RR FB-0500-03, Turbine Building Footprint - Survey Unit 3 (a MARSSIM Class 2 Survey), Table 2, Note 1, states, "[t]he Co-60 DCGL of 1.5 pCi/g is an adjusted DCGL and can be derived from the unitized dose for surface soil, LTP Table 6-7."

The resulting DCGL for Co-60 alone is 1.5 pCi/g.

The staff notes that in FSS-RR FB-0500-04, Turbine Building Footprint - Survey Unit 4 (a MARSSIM Class 1 Survey Area) Table 2, Note 1, "[t]he Co-60 DCGL of 0.86 pCi/g is an adjusted DCGL and can be derived from the unitized dose for surface soil, LTP Table 6-7 and the updated dose model in the activated concrete related license amendment (References 3 and 4)."

Given that the Turbine Building footprint is at an after backfill depth of 3 feet, the staff requires clarification of the following issues.

1. Please justify the use of the LTP Table 6-7, "Surface Soil Unitized Dose Factors 1.0 pCi/g Cs-137" versus LTP Table 6-9, "Deep Soil Unitized Dose Factors" to derive the adjusted Co-60 DCGLs for what appears to be a deep soil condition?
2. Since the deep soil DCGLs were not applied, the Staff questions whether the subsequent annual dose limits were applied properly. Please clarify the relationship between the LTP Table 6.9 Deep Soil Annual Dose value for Total Dose Co-60 of 2.4 mrem/yr, and the LTP Table 6-11 Contaminated Material Annual Dose (Deep Soil) value of 1.52 mrem/yr.
3. Even though Survey Units 3 and 4 are adjacent areas, two different Co-60 soil DCGLS were derived and applied. Survey Unit 3 uses a Co-60 DCGL of 1.5 pCi/g and Footnote 1 to Table 2 states that the relationship is not impacted the updated dose model in the activated concrete related license amendment (references 3 and 4). Whereas in Survey Unit 4, the Co-60 DCGL is 0.86 pCi/g and this amendment is referenced as the basis for deriving the Co-60 DCGL. Please clarify the use of two different DCGLs and the derivation bases.
4. Survey Unit 3, Investigation Table, Table 3-1, indicates that Grid S033 soil sample has specific activity of 0.968 pCi/g. Given the applicability of the Deep Soil Unitized Dose Factor, and an assumed lowering of the DCGL, it appears that this grid would have exceeded the DCGL and the survey unit should have been reclassified as a Class 1 area in accordance with LTP Table 5.8. In addition, it is noted that Grid S033 is bounded by areas that have been surveyed to ensure that activity was limited to this survey grid. Please address.

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